AML policy
AML / KYC / SoF Policy of WxMoney Service
1. Purpose and Scope of the AML Policy
The Anti-Money Laundering and Counter-Terrorist Financing (AML / CTF) Policy defines the principles, procedures, and control measures applied by WxMoney when providing digital asset exchange services. Purpose of the Policy:- preventing the use of the service for money laundering;
- reducing the risk of involving legitimate clients in unlawful activities of third parties;
- compliance with international AML standards and monitoring platform requirements.
2. Risk-Based Approach
2.1. Risk-Score Model
Transactions are evaluated using an AML bot whose data forms the basis of the Risk-Score model. Risk-Score is formed based on:- source of funds;
- transaction history;
- connections with high-risk categories;
- geographical and behavioral factors.
2.2. Threshold Values
- Low / Medium Risk — the exchange may be processed without additional procedures.
- High Risk (≥ 50%) — the transaction is temporarily suspended.
- Dark Market / Darknet Marketplace
- Mixer / Mixin
- Scam / Fraud
- Sanctions / High-Risk Jurisdiction
- Terrorism Financing
- Stolen Coins
- Illicit Actor / Organization
3. Preliminary AML Check and User’s Informed Choice
3.1. On the exchange creation page:
- a visible AML information block explaining the check;
- information about High-Risk consequences (suspension, data request, refund);
- the ability to perform a preliminary AML verification of an address or transaction is possible in our AML analyzer;
- a separate AML risk acknowledgment checkbox.
3.2. User Choice
- perform a preliminary AML check;
- refuse the check and accept all risks.
4. AML Analyzers Used
WxMoney uses AML bot data recognized as valid for operational decisions, suspension, KYC / SoF requests, and refunds.5. High-Risk and Sanctioned Sources
- sanction regimes;
- illegitimate services;
- darknet marketplaces;
- mixers;
- illegal gambling and financial platforms.
6. AML / KYC / SoF Procedures
6.1. Grounds for Verification
- Risk-Score threshold exceeded;
- connections to illegitimate sources detected;
- other high-risk indicators.
6.2. SoF Materials
- source of funds;
- sender platform / wallet;
- description of transaction;
- amount, date, and time;
- blockchain explorer links;
- screenshots if available.
6.3. KYC Documents
- passport / ID / driver’s license;
- selfie with document and current date;
- proof of address if required.
7. Verification Timeframe
Verification may take up to 7–14 business days after receiving full documentation.8. Refusal of KYC and Possible Outcomes
8.1. Refund
- refund to sender within 7–10 business days with tx hash confirmation;
- operational fee withheld (not exceeding 100 USDT);
- TRC-20 / ERC-20 / BEP-20 networks require native asset (TRX, ETH, BNB) for gas.
8.2. Official Escalation
Applied only if legally required, with information forwarded to competent authorities. No indefinite fund retention applies.9. High-Risk Transaction Fees
Additional fees apply solely to compensate:- enhanced AML analysis;
- operational and technical costs;
- risk mitigation measures.
10. Asset Storage During Verification
- funds may remain at the original address;
- or be transferred to a cold wallet.
11. Service Obligations
- store data for at least 3 years;
- analyze suspicious transactions;
- respond to official requests;
- suspend risky transactions;
- refuse operations if AML risks are detected.
12. Refund Restrictions
Refunds may be restricted only in the following cases:- official lawful request of competent authorities;
- seizure or legal blocking of assets.