AML policy

AML / KYC / SoF Policy of WxMoney Service

1. Purpose and Scope of the AML Policy

The Anti-Money Laundering and Counter-Terrorism Financing (AML / CTF) Policy defines the principles, procedures, and control measures applied by the WxMoney service when providing digital asset exchange services. The objectives of this policy are:

preventing the use of the service for the legalization of illegal income;
reducing the risks of involving bona fide users in the illegal activities of third parties;
compliance with international AML standards and requirements of monitoring platforms.

This Policy is mandatory for all Users and applies to all operations without exception.

2. Risk-Based Approach

2.1. Risk-Score Model

An AML bot is used to evaluate operations, the data of which forms the basis of the Risk-Score model. The Risk-Score is generated based on:

sources of asset origin;
transaction history;
links to high-risk categories;
geographical factors;
behavioral factors.

2.2. Threshold Values

Low / Medium Risk — the order can be completed without additional procedures.
High Risk (≥ 50%) — the execution of the order is temporarily suspended.

The grounds for an in-depth audit is the presence of ≥ 10% of tags from the following categories:

Dark Market / Darknet Marketplace;
Mixer / Mixin;
Scam / Fraud;
Sanctions / High-Risk Jurisdiction;
Terrorism Financing;
Stolen Coins;
Illicit Actor / Organization.

The list is not exhaustive. The results of the AML bot are decisive when making decisions on operations.

3. Preliminary AML Verification and Informed User Choice

3.1. The following is placed on the order creation page:

a visible AML block explaining the essence of the check;
information on the consequences of High-Risk status (suspension, data request, refund);
the ability to perform a preliminary AML check of an address or transaction via an AML analyzer;
a separate checkbox for consent to AML risks.

3.2. User's Choice

The User is obliged to explicitly choose one of the options:

undergo a preliminary AML check;
refuse the check and assume the risks.

Refusal of preliminary verification does not cancel the mandatory AML verification after the funds are received.

4. AML Analyzers Used

WxMoney uses data from an AML bot, the results of which are recognized as valid for:

making decisions on operations;
suspending orders;
requesting KYC / SoF;
refunding funds;
refusing to conduct an operation.

5. High-Risk and Sanctioned Sources

High-risk sources include:

sanction regimes;
illegitimate services;
darknet markets;
mixers;
illegal gambling and financial platforms;
other sources recognized as high-risk by AML systems.

The list may be updated without prior notice to Users.

5.1. Prohibited Platforms and Entities

WxMoney does not accept funds received directly or indirectly from the following platforms, services, organizations, and entities recognized as high-risk, sanctioned, illegitimate, or associated with illegal activities. If a transaction is found to be linked to the entities listed below, the order may be suspended, rejected, or sent for in-depth AML / KYC / SoF verification.

bitpapa.com
rapira.net
peer.com
payeer.com
capitalist.net
grinex.io
meer.kg
nobitex.ir
1xBet and all related entities
aifory.pro
terminal.cash
skycrypto.net
flashobmen.com
60cek.net
hd-change.com
coinblinker.com
metka.cc
alfabit.org
Garantex
Hydra
Blender.io
Lazarus Group
Genesis Market
ChipMixer
Sinbad
Bitzlato
netex24.net
BTC-e / FinCEN
weiss.bet
CryptoCloud
xRocket.tg
heleket.com
WebMoney
arvix.pro (abcex.io)
Prostocash
Cripta
CoinStart
kassa.cc
freekassa.ru
OFSI Huobi Global S.A. (HTX.com)

This list is not exhaustive and may be changed, supplemented, or updated without prior notice to Users.

6. AML / KYC / SoF Procedures

6.1. Grounds for Verification

Verification may be initiated in the following cases:

exceeding the Risk-Score threshold;
identifying links to illegitimate sources;
signs of bypassing AML controls;
other signs of increased risk.

6.2. Requested Materials (SoF)

As part of the verification, the User may be required to provide:

the source of asset acquisition;
the platform or wallet of the sender;
a description of the operation;
the amount, date, and time of the transaction;
links to transactions in the blockchain explorer;
screenshots of transaction history (if available).

6.3. KYC Documents

If necessary, the service has the right to request:

passport / ID card / driver's license;
a selfie with the document and the current date;
proof of residential address.

7. Verification Timelines

Verification is carried out within 7–14 business days from the receipt of a full package of documents and information.

8. Refusal of KYC and Acceptable Outcomes

8.1. Refund of Funds

In case of the User's refusal to undergo KYC / SoF, the service has the right to return the funds to the sender. Refund conditions:

refund period — from 7 to 10 business days;
refund is carried out after the User provides the correct tx hash;
a fee is deducted to cover operational and technical costs, but not more than 100 USDT.

For TRC-20, ERC-20, and BEP-20 networks, the presence of a native asset (TRX, ETH, or BNB) is required to pay the network fee (an equivalent of 5–10 USDT is recommended).

8.2. Official Escalation

Official escalation is applied exclusively in the presence of legal grounds and may be accompanied by the transfer of information to competent authorities. Indefinite retention of funds is not applied.

8.3. Processing Times for Non-Standard Situations

Refunds of payments sent without MEMO / Destination Tag / Payment ID are carried out within 3 (three) business days from the moment of receiving the correct address for the refund. Refunds of payments received in an unsupported currency or via an unsupported network are carried out within 7 (seven) business days. Crediting of payments previously returned to the WxMoney hot wallet is carried out within 7 (seven) business days from the moment the funds are received again. When an AML block is triggered:

the time to receive the final AML status is up to 24 hours;
if a refund decision is made, the refund is carried out within 3 (three) business days.

9. Fees for High-Risk Transactions

An additional fee may be applied exclusively to compensate for:

in-depth AML analysis;
operational and technical costs;
risk mitigation measures.

The amount of the fee is determined individually depending on the complexity of the audit.

10. Storage of Assets During Verification

For the period of the audit, funds may:

remain at the source address;
be placed on a hot or cold WxMoney wallet.

This is a technical feature of cryptocurrency processing and does not limit the User's right to a refund in the absence of legal restrictions.

11. Responsibilities of the Service

WxMoney undertakes to:

store data for at least 3 years;
analyze suspicious transactions;
provide information upon official requests from authorized bodies;
suspend operations in the presence of AML risks;
refuse to conduct operations upon identification of critical AML risks.

12. Restrictions on Refunds

Refunds may be restricted exclusively in the following cases:

in the presence of an official request from competent authorities, drawn up in accordance with applicable law;
in case of seizure, blocking, or other interim measures in relation to the relevant assets.

In all other cases, unreasonable or indefinite retention of funds is not allowed.

13. Person Responsible for AML Policy Compliance

WxMoney has appointed a responsible person who carries out:

control of compliance with AML / KYC procedures;
transaction monitoring;
interaction with competent authorities;
updating the risk assessment;
updating this Policy.

14. User's Consent to the AML Policy

By creating an order and using the WxMoney service, the User confirms:

familiarization with this AML / KYC / SoF Policy;
consent to the use of AML checks;
understanding of the possible consequences of High-Risk transactions;
readiness to provide information and documents upon request of the service within the framework of AML / KYC / SoF procedures.