AML policy

WxMoney AML / KYC / SoF Policy

1

Purpose and scope of the AML policy

The Anti-Money Laundering and Counter-Terrorist Financing (AML / CTF) Policy sets out the principles, procedures and control measures applied by the WxMoney service when providing digital asset exchange services. The objectives of this policy are:
  • to prevent the service from being used to launder illicit proceeds;
  • to reduce the risk of good-faith users being drawn into unlawful activity of third parties;
  • to comply with international AML standards and the requirements of monitoring platforms.
This Policy is mandatory for all Users and applies to all transactions without exception.
2

Risk-Based Approach

2.1. Risk-Score model

An AML bot is used to assess transactions; its data underlies the Risk-Score model. The Risk-Score is based on:
  • the origin of the assets;
  • the transaction history of the funds;
  • links to high-risk categories;
  • geographic factors;
  • behavioral factors.

2.2. Thresholds

Low / Medium Risk — the order may be processed without additional procedures.
High Risk (≥ 50%) — processing of the order is temporarily suspended.
Grounds for an enhanced review are the presence of ≥ 10% flags in the following categories:
Dark Market / Darknet MarketplaceMixer / MixinScam / FraudSanctions / High-Risk JurisdictionTerrorism FinancingStolen CoinsIllicit Actor / Organization
This list is not exhaustive. The AML bot results are decisive when making decisions on transactions.
3

Preliminary AML check and the User's informed choice

3.1. The order creation page displays:

  • a prominent AML block explaining the purpose of the check;
  • information on the consequences of High-Risk status (suspension, data request, refund);
  • the option to run a preliminary AML check of an address or transaction using the AML analyzer;
  • a separate checkbox confirming acceptance of AML risks.

3.2. User's choice

The User must explicitly choose one of the following options:
  • to undergo a preliminary AML check;
  • to decline the check and accept the risks.
Declining the preliminary check does not cancel the mandatory AML check after the funds are received.
4

AML analyzers used

WxMoney uses AML bot data, the results of which are recognized as valid for:
  • making decisions on transactions;
  • suspending orders;
  • requesting KYC / SoF;
  • refunding funds;
  • refusing to carry out a transaction.
5

High-risk and sanctioned sources

High-risk sources include:
  • sanctioned regimes;
  • illegitimate services;
  • darknet markets;
  • mixers;
  • illegal gambling and financial platforms;
  • other sources classified as high-risk by AML systems.
This 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 that are considered high-risk, sanctioned, illegitimate or linked to unlawful activity. If a transaction is found to be linked to the entities listed below, the order may be suspended, rejected or sent for an enhanced AML / KYC / SoF review.
bitpapa.comrapira.netpeer.compayeer.comcapitalist.netgrinex.iomeer.kgnobitex.ir1xBet*aifory.proterminal.cashskycrypto.netflashobmen.com60cek.nethd-change.comcoinblinker.commetka.ccalfabit.orgGarantexHydraBlender.ioLazarus GroupGenesis MarketChipMixerSinbadBitzlatonetex24.netBTC-e / FinCENweiss.betCryptoCloudxRocket.tgheleket.comWebMoneyarvix.pro (abcex.io)ProstocashCriptaCoinStartkassa.ccfreekassa.ruOFSI Huobi Global S.A. (HTX.com)
* 1xBet and all entities related to it. 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 a check

A check may be initiated in the following cases:
  • the Risk-Score threshold is exceeded;
  • links to illegitimate sources are identified;
  • signs of AML control evasion are present;
  • other signs of increased risk.

6.2. Materials requested (SoF)

As part of the check, the User may be required to provide:
  • the source of the assets;
  • the sender's platform or wallet;
  • a description of the transaction;
  • the amount, date and time of the transaction;
  • links to the transactions in a blockchain explorer;
  • screenshots of the transaction history (if available).

6.3. KYC documents

If necessary, the service may request:
  • a passport / ID card / driver's license;
  • a selfie with the document and the current date;
  • proof of residential address.
7

Review times

The check is carried out within 7–14 business days from receipt of the complete package of documents and information.
8

Refusal to complete KYC and permitted outcomes

8.1. Refund

If the User refuses to complete KYC / SoF, the service may return the funds to the sender. Refund conditions:
  • the refund period is 7 to 10 business days;
  • the refund is made after the User provides a correct tx hash;
  • a fee is withheld to cover operational and technical costs, but no more than 100 USDT.
For TRC-20, ERC-20 and BEP-20 networks, 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 only where there are lawful grounds and may involve passing information to the competent authorities.
Indefinite retention of funds is not applied.

8.3. Processing times for non-standard situations

  1. Payments sent without a MEMO / Destination Tag / Payment ID are refunded within 3 (three) business days of receiving a correct refund address.
  2. Payments received in an unsupported currency or through an unsupported network are refunded within 7 (seven) business days.
  3. Payments previously returned to the WxMoney hot wallet are credited within 7 (seven) business days of the funds being received again.
  4. In the event of a refund, if an extremely high level of risk is identified due to the nature of the transaction, the origin or movement of funds, a fee of 5% of the refund amount may be withheld, but not more than 100 USDT.
    The fee is withheld to cover the costs associated with conducting additional checks, processing, and returning the funds.
  If an AML block is triggered:
  • the final AML status is obtained within 24 hours;
  • if a refund is decided on, it is made within 3 (three) business days.
9

Fees for High-Risk transactions

An additional fee may be applied solely to compensate for:
  • in-depth AML analysis;
  • operational and technical costs;
  • risk mitigation measures.
The fee is determined individually depending on the complexity of the check.
10

Storage of assets during the check

During the check, funds may:
  • remain at the original address;
  • be held in a WxMoney hot or cold wallet.
This is a technical feature of cryptocurrency processing and does not restrict the User's right to a refund in the absence of legal restrictions.
11

Obligations of the service

WxMoney undertakes to:
  • retain data for at least 3 years;
  • analyze suspicious transactions;
  • provide information upon official requests from authorized bodies;
  • suspend transactions where AML risks are present;
  • refuse to carry out transactions where critical AML risks are identified.
12

Restrictions on refunds

A refund may be restricted solely in the following cases:
  • an official request from competent authorities, issued in accordance with applicable law;
  • seizure, blocking or other security measures imposed on the relevant assets.
In all other cases, unjustified or indefinite retention of funds is not permitted.
13

Person responsible for AML policy compliance

WxMoney has appointed a responsible person who:
  • oversees compliance with AML / KYC procedures;
  • monitors transactions;
  • liaises with competent authorities;
  • updates the risk assessment;
  • keeps this Policy up to date.
14

User's consent to the AML policy

By creating an order and using the WxMoney service, the User confirms:
  • that they have read this AML / KYC / SoF Policy;
  • their consent to the application of AML checks;
  • that they understand the possible consequences of High-Risk transactions;
  • their readiness to provide information and documents upon the service's request as part of AML / KYC / SoF procedures.

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