AML and KYC - Policy

Effective Date: March 3, 2026

Applicability: This Policy applies to all users and all operations performed through the service, including cryptocurrency and bank card transactions.

This Policy defines the principles and procedures for Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF), as well as the procedures for customer identification and verification (KYC), Source of Funds verification (SoF), and payment instrument verification.

The Service applies a risk-based approach and uses a combination of automated AML analysis tools and manual compliance review.

• AML (Anti-Money Laundering) – measures aimed at preventing money laundering.

• KYC (Know Your Customer) – procedures for identifying and verifying the identity of a customer.

• SoF (Source of Funds) – verification of the origin of funds used in transactions.

• Risk Score – a numerical indicator of the risk level of a blockchain address, transaction, or asset based on AML analysis.

• User / Client – any person using the Service to perform exchange operations.

• Payment Instrument – a bank card or other payment method used by the user.

The Service applies a risk assessment model based on:

• results from AML analytical tools;

• type of asset and blockchain network;

• transaction history;

• association of addresses with known clusters (exchanges, mixers, darknet markets, sanctioned or otherwise high-risk entities);

• parameters related to payment instruments (including bank cards).

• Low Risk — Risk Score up to 50%. Transactions are processed in standard mode. (<29%)

• Medium Risk — Risk Score requiring additional verification. The transaction may be temporarily suspended for review. (>30% - <49%)

• High Risk — Risk Score exceeding internal thresholds. The transaction is suspended and KYC/SoF procedures may be initiated. (>50%)

The Risk Score threshold for standard transaction processing does not exceed 29%. Internal thresholds may be adjusted depending on regulatory or industry requirements.

The Service uses the following AML tools and systems:

• AML Bot

• GetBlock

• All incoming transactions undergo mandatory KYC checks using the Rapira AML analyzer

These tools are used for:

• monitoring incoming and outgoing transactions;

• assessing wallet addresses and transactions through Risk Score;

• identifying connections to high-risk entities;

• detecting suspicious activity.

The results of AML analysis may serve as grounds for:

• processing a transaction;

• temporarily suspending a transaction;

• requesting additional information from the user;

• initiating KYC, SoF, or payment instrument verification procedures.

The Service implements the following safeguards:

• verification of incoming and outgoing transactions;

• use of unique (one-time) cryptocurrency addresses for each client;

• clustering of addresses associated with the Service;

• consolidation of funds to the Service’s main wallet after initial verification;

• cooperation only with verified liquidity providers with low-risk profiles.

The purpose of these measures is to prevent the distribution of high-risk digital assets to users.

For transactions using bank cards, the service reserves the right to check and verify the payment instrument.

Card verification may include:

providing a photo or screenshot of the card by the user (with part of the card number and CVV code obscured);

confirming card ownership;

comparing the cardholder's details with the details of the user undergoing KYC.

Credit Verification Rule

To ensure security, prevent fraud, and comply with the Company's internal procedures, when conducting crypto-fiat transactions, the Company reserves the right to request additional confirmation from the Client that funds have been credited to the bank account.

Upon request by the operator in the chat, the Client may be invited to provide one or more of the following:

a photo or screenshot from their personal bank account showing the deposits and/or current balance for the relevant account associated with a specific transaction;

a short video demonstrating logging into their personal bank account and displaying the movement of funds (deposits) in the account to confirm the presence or absence of deposits for the specified amounts.

Current Account Statement

These materials are used solely to verify the accuracy of the amount and the fact of crediting funds for a specific transaction and are not shared with third parties, except in cases expressly provided for by applicable law.

The Client's refusal to provide the requested data may be grounds for suspension, cancellation, and/or denial of further processing of the transaction until verification is completed.

The Service reserves the right to refuse a card transaction if it detects signs of increased risk, data inconsistency, or the user refuses to undergo verification.

Users have the option to perform a preliminary AML check of a cryptocurrency address before submitting a request.

This feature is available in the website header under the “AML analysis” section and redirects to the AML verification page of the BestChange service:

https://www.bestchange.ru/report/

The preliminary AML check can be carried out by the user on a paid basis using reliable AML tools, including those provided by BestChange or third-party AML services.

Based on the results of the check, the user is given a choice:

- to share the AML check results with the service operator for a preliminary assessment of whether the exchange can be processed;

- or to decline sharing the results while confirming acceptance of potential risks, including the possibility of transaction suspension during a KYT check.

As part of AML compliance procedures, the Service may request additional information from the user when conducting an AML review. The user may be asked to answer one or more of the following questions and provide supporting documentation:

• What is your current employment status?

• What are your sources of income?

• Through which source did the funds reach you before you deposited them to our platform from your wallet? Please provide transaction history, including deposits and withdrawals from the originating platform to the wallet from which the funds were later sent to our Service.

• What was the purpose of receiving the funds to your wallet or platform? Please provide confirmation of the withdrawal from the originating platform to your wallet.

• If the sender of the funds was a third party and not yourself, please provide supporting correspondence or documentation confirming the receipt of the funds or payment.

Please note that this information is requested in accordance with the Service’s internal AML policy.

All information and documents provided by the user are stored in encrypted form on a separate secure storage device and are used exclusively for AML compliance purposes.

Photos of identification documents and answers to the questions above should be sent to [email protected] with the exchange order number and the subject line "AML refund request".

KYC verification may be required in the following cases:

• Risk Score exceeding internal thresholds;

• suspicious transaction patterns;

• use of bank cards or other payment instruments requiring additional verification;

• requirements of applicable laws or partner institutions;

• other situations deemed necessary by the Service under a risk-based approach.

During KYC verification, the Service may request:

• a government-issued identity document;

• a selfie or video verification;

• proof of address (if necessary);

• a copy or image of a bank card with sensitive data partially hidden if the transaction involves card payments;

• any additional information required to verify the user’s identity.

When necessary, the user may be required to provide documents confirming the lawful origin of funds, including but not limited to:

• exchange account screenshots;

• transaction history;

• contracts or documents confirming receipt of funds;

• other relevant financial documentation.

• Initial AML review is typically completed within 24 hours.

• KYC, SoF, and/or card verification procedures may take up to 3 business days after all requested information has been submitted.

• In complex cases the review period may be extended, and the user will be notified accordingly.

• During the review process, the transaction may be temporarily suspended.

The Service reserves the right to refuse a transaction or terminate service in the following cases:

• failure to provide requested information;

• evidence linking funds or payment instruments to illegal activities;

• submission of false or misleading information;

• violation of this Policy or the Service Rules.

To mitigate AML/CFT risks, Almazex does not provide services to users who are located in, registered in, or otherwise connected to jurisdictions classified as high-risk or prohibited under international standards and industry guidelines (including recommendations of the Financial Action Task Force, as well as UN, EU, and other sanctions lists).

Users from the following countries and territories are not serviced, and any received funds will be returned to the sender where legally permissible: United States, Afghanistan, Albania, Angola, Algeria, Barbados, Bolivia, Botswana, Myanmar (Burma), Burundi, Cambodia, Central African Republic, Chad, Congo, Guinea, Côte d’Ivoire, Cuba, North Korea (DPRK), Ecuador, Egypt, Equatorial Guinea, Eritrea, Ghana, Guinea-Bissau, Haiti, Guyana, Iran, Iraq, Laos, Lebanon, Libya, Mali, Morocco, Nepal, Nicaragua, North Macedonia, Pakistan, Panama, Qatar, Saudi Arabia, Somalia, South Sudan, Sudan, Syria, Tunisia, Uganda, Vanuatu, Venezuela, Yemen, Zimbabwe, Jamaica.

Regarding the source of funds, transactions associated with the following services are not accepted: Rapira, HTX, Grinex, Trustee Plus, Kraken, Bitpapa, EXMO, ABCeX, Aifory Pro, Shelbit, Aban Tether Exchange.

Almazex reserves the right to update and modify the list of high-risk jurisdictions at any time in response to changes in international sanctions, FATF recommendations, and monitoring requirements, without prior notice to users.

• If a refund is required as part of AML procedures, the refund period may take up to 10 business days after completion of all compliance checks.

• The refund fee does not exceed 10% of the blocked amount and not more than 100 USD equivalent.

• For legitimate users whose funds are not linked to illicit activity after KYC/SoF verification, the fee will be limited strictly to applicable blockchain network fees.

The Service ensures:

• collection of personal data only to the extent necessary for AML/KYC compliance and payment verification;

• storage of data using appropriate technical and organizational security measures;

• restricted access to authorized personnel only;

• use of collected data solely for AML/CTF compliance and legal obligations.

Detailed conditions for personal data processing are described in the Service Privacy Policy.

Before creating an exchange request, the user must confirm acceptance of:

• the Service Rules;

• this AML & KYC Policy;

• the Privacy Policy.

Without such confirmation, the Service cannot be used.

The Service reserves the right to amend this Policy at any time. The current version is always published on the website and becomes effective upon publication.

For any AML/KYC-related inquiries, users may contact the Service support team via the official communication channels listed on the website.