This Policy establishes a set of rules and procedures aimed at preventing the legalization (laundering) of proceeds obtained unlawfully, terrorist financing, as well as identifying customers and monitoring transactions carried out. Its application is intended to protect BTC2PAY and its Users from involvement in unlawful activities. Each Application is subject to a mandatory AML check. Where necessary, the User is entitled to independently and in advance verify whether their cryptocurrency wallet complies with AML requirements before transferring funds; for this purpose, the AML Checker may be used. If the wallet address is unknown to the User, or the User is unable or refuses to undergo a preliminary AML check, where the aggregate AML risk level exceeds the threshold of 60%, the exchange shall be suspended and the funds shall be returned less the network fee, in accordance with the procedure set forth in the User Agreement.

1. Key Terms

BTC2PAY means an online platform intended for the exchange, purchase and sale of cryptocurrencies and other digital assets. User means an individual or legal entity using the BTC2PAY service. Cryptocurrency means a digital means of exchange operating on the basis of blockchain technology. Electronic Currency means funds circulating within electronic payment systems. Money Laundering means giving an appearance of legitimacy to the possession, use or disposal of funds obtained through criminal activity. Terrorist Financing means the provision or collection of funds with the intention that they be used to commit terrorist acts.

2. Preliminary AML Check of a Cryptocurrency Wallet

Before creating an exchange Application, the User is entitled to independently verify the reliability of their cryptocurrency wallet using the AML Checker. To do so, the User must register on the Website and purchase a package of checks in the Personal Account.

2.1. Registration on the Website

Creating an account is a mandatory requirement for using the AML Checker.

• Click the "Registration" button in the upper-right corner of the Website.
• Provide the following information:
  • email address;
  • password.
• Complete the registration by following the link sent to the specified email address.

Upon completion of the confirmation procedure, the User is granted access to the Personal Account.

2.2. Purchase of an AML Check Package

The AML check is provided on a paid basis under a package system.

1. Log in to the Personal Account.
2. Click the “Buy Checks” button.
3. Select the appropriate package of checks.
4. Click the “Proceed to Payment” button.
5. The system will generate an address for making the deposit. Send the payment to the specified address. Once the deposit has been successfully credited, the number of available checks will be displayed in the Personal Account, after which they may be used immediately for AML checks of wallets.

2.3. AML Check Procedure

1. In the Personal Account, go to the “AML Checks” section and click the “New Check” button.
2. Enter the address of the cryptocurrency wallet from which the funds are intended to be sent.
3. Select the relevant network: BTC, ETH, TRC-20, etc.
4. Click the “Check” button. The system will deduct 1 check from the available package, after which the analysis result will be provided.

2.4. Submission of the Result to the Operator

Upon completion of the AML check, the result is automatically sent by the system to the User’s email address. Further actions shall depend on the established risk level:

• If the risk level does not exceed 60%, the User is entitled to use the wallet for the exchange without taking any additional action.
• If the risk level exceeds 60%, the User is required to submit the check result to the operator via the online chat on the Website.

When sending the message, the User must specify:

• the checked wallet address;
• the date of the check;
• a brief description of the result obtained.

The operator reviews the submitted result and informs the User whether funds may be sent from the relevant wallet. Important: notifications regarding an elevated risk level must not be ignored; taking such notifications into account is a mandatory requirement of the Service’s AML Policy.

3. Policy Objectives

• Preventing the use of the platform for unlawful purposes.
• Ensuring compliance with applicable legal requirements and international standards.
• Strengthening User security and the Company’s reputational resilience.

4. Policy Components

4.1. AML/CTF

• Identification of customers and verification of the source of funds.
• Monitoring transactions for the purpose of detecting suspicious activity.

4.2. KYC

• Collection and verification of personal and financial information about the customer.
• Contact and personal data provided by the User when creating an Application must meet the criteria of completeness, accuracy and relevance.
• BTC2PAY ensures the protection, storage and processing of such data in accordance with the User Agreement and applicable law.
• Users’ personal data is not transferred to third-party AML providers. For transaction analysis purposes, automated blockchain analytics tools may be used, in which case only technical transaction data, including cryptocurrency wallet addresses and transaction hashes, is processed, without transferring the User’s personal data.

4.3. KYT

• Analysis of transactional activity for the purpose of identifying fraudulent or unlawful transactions.
• Suspension of suspicious transactions until information confirming their legitimacy is obtained.
• Verification of the source of funds.

4.4. Handling High-Risk Transactions

The Service uses automated blockchain analytics systems that enable the detection of signs of suspicious activity and transaction risk markers. As part of the review, transaction risk indicators are analyzed, including any potential connection with high-risk sources, fraudulent schemes, sanctioned services and other categories of suspicious activity. If, based on the results of the automated review, the aggregate risk level exceeds 60% and a connection with high-risk sources listed in Section 4.5 of this Policy is established, the transaction may be temporarily suspended for additional review and for a decision to be made regarding the return of funds to the User less the network fee. If a decision is made to return the funds, the relevant procedure may take up to 7 (seven) business days. The status of the transaction is determined on the basis of a comprehensive automated analysis of transaction data and an AML/KYT review.

4.5. Categories of High-Risk Sources

BTC2PAY reserves the right to block funds received from exchanges included in sanctions lists or designated as “high-risk”. As of the current date, such platforms include: Black Sprut, BTC-e, Chiper Mixer, DuelBits, FreeBitcoin, Gandhiji.io, Hydra, NVSPC, Roobet, Tornado, WEX Exchange, Yolo Group, OMG!OMG!, Garantex, Commex, Tornado Cash, 1xBit, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, MEGA DARKNET MARKET, Primedice, Darknetone, Wasabi Wallet, DuckDice, Doubleway, Stake, Stolen Coins, Fraudulent Exchanges, Terrorism Financing, Bitzlato, Bitpapa.com, NetEx24.net, Trocador.app, Anonexch.io, Cryptomus, nobitex.ir, meer.kg, 1xbet, Aifory.pro, terminal.cash, SkyCrypto.net, FlashObmen.com, 60cek.net, hd-change.com, CoinBlinker.com, Metka.cc, AlfaBit.org, Heleket, payeer.com, Vexel, Fun Pay, Web Money, Freekassa, Yobit, exmo.com, exmo.me, Crypto Cloud, Cripta, BitBits, Nix Money, Bixter, freekassa.ru, kassa.cc, CoinStart, Prostocash, arvix.pro (abcex.io), heleket.com, xRocket.tg, CryptoCloud, weiss.bet, BTC-e / FinCEN, Sinbad, OFSI Huobi Global S.A. (HTX.com), as well as platforms from other sanctioned countries and services focused on anonymity and privacy. This list may be supplemented. Risk categories: Sanctions, Terrorism, Darknet, Ransomware/Malware, Mixing, Child Abuse, Stolen Funds, Scam/Fraud, Protocol Privacy, Bridge, Decentralized Exchange, Gambling. BTC2PAY shall not be liable for funds received from the above sources and is entitled to provide the relevant information to competent authorities.

4.6. Procedure for Returning Funds in the Event of an Unsuccessful AML Check

If, based on the results of the automated review, the aggregate risk level exceeds 60% and a connection with high-risk sources listed in Section 4.5 of this Policy is established, the transaction may be temporarily suspended for additional review and for a decision to be made regarding the return of funds to the User. In the event of an AML block:

• up to 24 hours — to determine the final status of the review;
• up to 7 (seven) business days from receipt of the wallet address — to process the return;
• in rare cases, the period during which funds are held may be up to 30 (thirty) business days if completion of the AML/KYT review requires additional analysis, receipt of information from third parties, or completion of procedures by external AML providers or platforms involved in processing the transaction.

Fees and Costs Applicable to the Return of Funds When a return is processed, the following amounts may be deducted from the amount to be returned:

• the actual blockchain network fee (Network fee);
• documented costs of AML, payment or other providers incurred in connection with the review, processing or unblocking of the transaction;
• additional costs associated with the return of funds — in an amount not exceeding 5% of the blocked funds, but in any event not exceeding USD 100 equivalent.

Technical requirements for returning USDT. To process a return in the TRC-20, ERC-20 and BEP-20 networks, the address from which the funds were sent may need to hold the relevant native asset to pay the network fee:

• TRX — for the TRC-20 network;
• ETH — for the ERC-20 network;
• BNB — for the BEP-20 network.

The recommended available balance of the native asset for covering the network fee is the equivalent of 3–5 USDT. If the native asset balance is insufficient, the User may be requested to top up the relevant address in advance by the amount required to process the return.

5. Rights and Obligations of the Service

BTC2PAY reserves the right to:

• Suspend and block transactions.
• Request additional documents and proof of identity from the User.
• Require the User to complete video verification for identity confirmation purposes.
• Provide relevant information to regulatory or law enforcement authorities.
• Return funds to the account from which the deposit was made and terminate further interaction with the customer.
• If the User does not contact the Service for more than 6 (six) months with a request for the return of funds blocked as a result of AML checks conducted by third parties, including centralized exchanges whose wallets are involved in the execution of the Application, BTC2PAY is entitled, at its sole discretion, to determine the form of such return: in USDT or in the relevant token, at the exchange rate applicable on the date the Application was created or at the exchange rate applicable on the date of the return.