Anti-Money Laundering (AML) Policy, KYC, and KYT Procedures

Revised as of: March 26, 2026

1. Introduction and Policy Objectives

This policy describes the principles and procedures of AML (Anti-Money Laundering) control applied by the Cryptomat service to ensure transaction security and compliance with international standards (FATF, 5AMLD/6AMLD). We are committed to protecting our clients from fraud and preventing the use of the platform for illegal activities.

2. Analysis Tools and Risk-Score Model

For the automated verification of cryptocurrency transactions, the service uses data from specialized AML analyzers: Rapira, BitOK, GetBlock. A Risk Score is generated based on their data.

The system evaluates the origin of funds by analyzing connections with high-risk categories. We adhere to the following transaction processing model:

Regardless of the overall Risk Score, a transaction is suspended for review if the following "red flags" are identified:

• Sanctioned or undesirable services: Garantex, CommEx, TornadoCash, Payeer, WhiteBit, and others.

• Critical Risk (> 0%): Terrorist Financing, Child Abuse, Human Trafficking, Fraudulent Exchange, Sanctions, Enforcement action, High-Risk Jurisdiction

• High Risk (> 1%): Darknet Market, Mixer, Stolen Funds, Ransomware, Illegal Service, Fraud Shop, Gambling, Scam, Illicit Actor/Organization.

3. Grounds for Transaction Suspension

The service has the right to suspend an operation if:

1. The transaction's Risk Score exceeds established thresholds (> 50%).

2. Direct links to addresses from "blacklists" or sanctioned platforms are identified.

3. The user employs anonymization tools (VPN, TOR, Proxy) or provides false data.

4. The amount or nature of the operation deviates significantly from the user's typical behavior.

4. Verification Procedure (KYC/SoF)

If a transaction is suspended (AML Hold), the user must undergo an identification procedure consisting of the following stages:

1. Submission of documents: A photo of a government-issued ID (passport, ID card) and a selfie with it.

2. Video verification: Recording a short video where the user, holding their passport, confirms the creation of order No. [ID], states the date, and confirms ownership of the assets.

3. Source of Funds (SoF) confirmation: Screenshots or video from the personal account of the platform from which the funds were sent, demonstrating the history of the asset's origin.

Verification timeframe: Initial document analysis takes from 10 minutes to 24 hours. In complex cases, it may take up to 7 business days.

5. Refund Terms and Conditions

The service adheres to the principles of fairness and transparency when returning blocked assets.

5.1. Simplified Refund (99% of cases without KYC)

In most situations where the risk is caused by indirect links (e.g., a transaction with a High-Risk Exchange or Gambling), we offer a refund without mandatory KYC.

• The refund is issued strictly to the original sender's address.

• Refund processing time: usually 1 business day (up to a maximum of 3 business days).

5.2. Refunds for Good-Faith Clients

If a client has passed the KYC/SoF procedure and their funds are not confirmed to be linked to money laundering (even with a high Risk Score), the refund is processed under the following conditions:

• The exchange fee is not charged.

• Only the actual network fee for the transfer is withheld.

5.3. Refunds for AML Incidents (High Risk)

In cases where verification is not completed or funds have a confirmed link to illegal activities, a fee is charged to cover operational expenses:

• Fee amount: no more than 5% of the total amount, but not exceeding $100 USD in equivalent.

Important: Funds will not be returned if they are blocked by a direct request from law enforcement or international regulators.

6. Preliminary AML Check

We strongly recommend that users conduct an independent check of their addresses before making an exchange. This can be done through a valid analyzer via the link:

👉 Check address on BestChange

Note: Results from third-party public analyzers are for informational purposes only. In the event of a discrepancy, priority in making a decision to block or verify a transaction is given to the data from the internal monitoring systems and professional analysis tools used by the Service (see Section 2). The Service is not responsible for any inconsistency between the results of external checks and internal Risk Score indicators.

7. Confidentiality

All data provided as part of KYC/AML procedures is stored in encrypted form in accordance with the privacy policy and is used exclusively for financial monitoring purposes.