# AML and KYC Policy

coinchain.exchange Anti-Money Laundering and Anti-Terrorist Financing Policy (hereinafter the AML Policy) and Know Your Customer Policy (hereinafter the KYC Policy) are intended to prevent and reduce the possible risks of the coinchain.exchange service participating in any illegal activity.

The service is operated by NewGenIT Ltd. (registration number 246535, registered address: House Of Francis, Room 303, Ile Du Port, Mahe, Seychelles).

International laws and regulators, as well as the Fifth Anti-Money Laundering and Anti-Terrorism Financing Directive (5AMLD), require the coinchain.exchange service to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, weapons of mass destruction, corruption and bribery, as well as to take action in case of any form of suspicious activity by its Users.

As a provider of virtual/cryptocurrency asset exchange services, we are obliged to verify all suspicious virtual/cryptocurrency asset transactions. During verification, among other things, it is necessary to carry out user identification (KYC) and establish the origin of the virtual/cryptocurrency asset. During the period of transaction verification, the virtual/cryptocurrency asset must be kept on the balance sheet.

By creating an order on the website, the Client agrees that an AML/KYC check may be carried out against them.

1. AML/KYC procedures

1.1. The AML/KYC verification procedure for clients and transactions is carried out by the AML officer of the coinchain.exchange service, as well as by our liquidity provider, namely the cryptocurrency exchange.

1.2. As part of the AML/KYC check, the Client consents to the processing and storage of their personal data, and, if necessary, to the transfer of this data to the liquidity provider, namely the AML officer of the cryptocurrency exchange.

1.3. The AML/KYC procedure includes a set of developed measures:

  • Continuous monitoring of transactions passing through the coinchain.exchange service;
  • Appointment of a responsible person (Money Laundering Reporting Officer);
  • Risk-based approach;
  • Customer Due Diligence;
  • Improving the professional skills and knowledge of coinchain.exchange service employees;
  • Interaction with government authorities in cases established by law;
  • Bookkeeping, accounting, and record keeping.

2. Transaction freezing and high-risk labels

If, based on the results of the analysis of AML cryptocurrency assets, a risk higher than 40% is identified, or any of the following labels are received:

  • DARK SERVICE
  • SCAM
  • STOLEN
  • MIXING (MIXER)
  • SEXTORTION
  • RANSOMWARE
  • HACK
  • PHISHING
  • TERRORISM FINANCING
  • FRAUD
  • BLACKLIST
  • STILL UNDER INVESTIGATION
  • CYBERCRIME ORGANIZATION
  • NARCOTICS
  • CHILD ABUSE
  • HUMAN TRAFFICKING
  • SANCTIONS
  • GAMBLING (Casino, Betting, etc.)

and other high-risk assets, the Client's transaction may be frozen for an indefinite period until complete identification verification (KYC) is completed.

2.1. Upon receipt of a service request from our liquidity provider, namely a cryptocurrency exchange, the Client's transaction may be frozen indefinitely until complete identification verification (KYC) is completed.

2.2. Upon receipt of a request from the competent authorities, the Client's transaction may be frozen for an indefinite period until complete completion of identity verification (KYC).

2.3. If any suspicious activity is detected by the AML officer of the coinchain.exchange service, the Client's transaction may be frozen for an indefinite period until complete identification verification (KYC) is completed.

3. Documents for KYC verification

To confirm the origin of funds, we ask you to fully answer the following questions:

  • Through which platform did the funds reach you? Please provide screenshots of the withdrawal history of the sender's wallet/platform, as well as links to both transactions in the explorer.
  • What service did you receive funds for?
  • What was the amount of the transaction, as well as the date and time it was carried out?
  • Which contact person did you use to communicate with the sender of the funds? Please provide screenshots of correspondence with the sender where we can see confirmation of sending funds.

We also ask you to provide the following materials:

  • A photo of one of the documents (passport, ID card, or driver's license);
  • A selfie with this document and a sheet of paper on which today's date and signature are written by hand.

If necessary, the service has the right to additionally request any other documents not listed in this section. All submitted images (scans, photos, screenshots) must be in JPEG or PNG format.

3.1. The time frame for reviewing documents for passing a KYC check is individual for each case and is not regulated by a fixed period.

3.2. Return of blocked assets is possible only after passing a KYC check.

3.3. User assets that have not passed AML verification cannot be exchanged.

3.4. Based on the results of a positive KYC check, the client will be refunded with a commission of 5%.

3.5. Return (refund) after completion of KYC verification is possible only to the address from which the cryptocurrency was sent.

4. Additional fee for high-risk transactions

Please note that our service reserves the right to charge an additional fee of up to 5% on transactions if they have high-risk characteristics, such as:

  • DARK SERVICE
  • SCAM
  • STOLEN
  • MIXING (MIXER)
  • SEXTORTION
  • RANSOMWARE
  • HACK
  • PHISHING
  • TERRORISM FINANCING
  • FRAUD
  • BLACKLIST
  • STILL UNDER INVESTIGATION
  • CYBERCRIME ORGANIZATION
  • NARCOTICS
  • CHILD ABUSE
  • HUMAN TRAFFICKING
  • SANCTIONS
  • GAMBLING (Casino, Betting, etc.)

This additional fee is applied to compensate for the additional analysis and risk mitigation measures required to process high-risk transactions.

5. Restrictions on return of assets

The return of assets is not possible if a request has been received for these assets from the competent authorities or a seizure/blocking has been imposed by other departments of any jurisdiction (in this case, the blocked asset can be passed as material evidence), or by decision of the liquidity provider to withhold funds.

5.1. Asset refunds on transactions with erroneous transfers, as well as AML-related checks and blocks, are not possible without full KYC verification.

6. Client cooperation deadline

Return of assets is not possible if the Client does not provide the information requested by the coinchain.exchange AML Officer by email at help@coinchain.exchange within 30 calendar days.

7. Prohibited and high-risk sources

Blocking is also carried out when sending assets from the following exchanges and platforms: Garantex, Tornado Cash, Hydra, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, Commex, as well as from any Iranian platforms and other platforms of prohibited/sanctioned countries and operations from DarkMarket resources.

7.1. FreeWallet, Join Market Project, Railgun, Rapira, Capitalist, Nobitex, and Wasabi Wallet services may also be considered high risk for coinchain.exchange; transactions related to these platforms may fall under AML blockages.

8. Liquidity provider discretion

The liquidity provider, as the initiator of the blockchain transaction flow, has the right to refuse to pay out frozen funds after passing AML verification in the cases described in clause 2, clause 2.3, and clause 7.

9. Pre-exchange inquiries

The Client has the right to contact technical support via Live Chat on coinchain.exchange to find out about the probability of blocking before creating an exchange.