1. General Provisions
1.1. This AML/KYC Policy (hereinafter referred to as the “Policy”) governs the procedures for countering money laundering and terrorist financing, as well as the customer identification (KYC) process at the UnionXbit exchange service (hereinafter referred to as the “Service”).
1.2. The Service adheres to international AML/KYC standards to minimize risks and ensure the security of transactions.
1.3. By using the Service, the User confirms:
- consent to this Policy;
- responsibility for the legality of the source of funds;
- consent to transaction verification within the AML/KYC framework.
2. Terms and Definitions
- AML (Anti-Money Laundering) — measures to counter money laundering.
- KYC (Know Your Customer) — the procedure for identifying a user and verifying the data provided.
- User — a capable natural person over 18 years of age or a legal entity using the services of the Service.
- Funds — cryptocurrency, electronic money, fiat funds.
- High-Risk Assets — funds showing signs of connection with illegal activity (Mixer, Sanctions, Ransom, Scam, Dark Market, Dark Service, Stolen Coins, Terrorism Financing, Fraudulent Exchange, Illegal Service, Child Exploitation, Enforcement Action, High-Risk Jurisdiction, Special Measures, etc.).
- Risk Score — a numerical assessment of a transaction’s risk level (from 0 to 100) provided by AML analyzers.
- Sanctions Lists — lists of individuals, organizations, and jurisdictions subject to international sanctions (UN, OFAC, EU, etc.).
3. KYC Procedures
3.1. Registration and Verification:
- The User provides accurate data during registration (email address, phone number).
- Depending on the risk level and transaction amount, the Service may request additional documents: passport, proof of address, card photo, video verification, and other data.
3.2. Data Verification:
- The Service verifies the accuracy of the data provided.
- In case of suspicious activity, transactions may be temporarily suspended pending clarification, with notification to the user.
3.3. Data updаte:
- The User is obliged to updаte their data in a timely manner.
- The Service may request updated information at any time.
3.4. All data obtained within the KYC framework is stored in a protected form for at least 5 years.
4. AML Procedures
4.1. Transaction Monitoring:
- The Service monitors transactions for suspicious activity using specialized services (Getblock, Crystal and/or other AML analyzers).
- A Risk Score is assigned to transactions based on analyzer data.
4.2. Risk Levels and Actions:
- Low Risk (up to 25%) – transactions are processed automatically without delays.
- Medium Risk (25–75%) – selective verification (KYC) or a request for source of funds confirmation may be applied.
- High Risk (over 75%) – the operation is suspended. Order execution is blocked until the user completes the full verification procedure.
4.3. Freezing of Funds:
- If money laundering or terrorist financing is suspected, funds may be temporarily frozen with notification to the user.
- If a connection with illegal activity is confirmed, information may be transferred to competent authorities.
4.4. Refusal to Accept Payments:
- The Service does not accept funds from wallets, exchanges, or platforms subject to sanctions, nor from jurisdictions included in the prohibited list (Appendix 1).
- Such transactions are frozen pending verification or rejected.
4.5. Commission for AML Case Processing: The Service has the right to withhold a commission of up to 5% of the transaction amount, but not exceeding $100 equivalent.
4.6. Temporary Operational Restrictions:
- In the event of circumstances beyond the Service’s control (including blocking or restriction of exchanges and payment infrastructure used by the Service), operations may be temporarily suspended.
- Resumption of operations and fund withdrawal occurs after the said restrictions are lifted.
- The period of fund retention depends on the nature and duration of the restrictions and cannot be determined in advance.
5. KYC Video Verification
To complete verification, the user provides a video selfie with their passport and demonstrates:
- the wallet from which the funds were sent;
- the amount and hash (ID) of the transaction;
- the recipient’s address.
- Video requirements: continuous recording, clear visibility of data, recording via camera (not a screenshot).
6. Return of Funds after KYC
6.1. Return of funds is possible only after successful KYC verification.
6.2. Return period: within 48 hours after the data is provided.
6.3. Return commission: funds are returned in full minus the network fee. In cases specified in clause 4.5, an additional commission for AML case processing may apply.
6.4. Funds unclaimed within 60 calendar days are considered dormant and are processed according to the internal return procedure.
6.5. Return is impossible if an official request has been received from payment systems or government authorities regarding the assets.
7. Data Protection
Users’ personal data is protected in accordance with the Privacy Policy posted on the Website.
8. User’s Responsibility
The User undertakes to:
- not use the Service for illegal operations;
- comply with this AML/KYC Policy;
- verify the legality of their assets before sending.
9. Policy Changes
The Service reserves the right to make changes. The current version comes into force upon publication on the website.
10. Self-Verification of Transactions
Users can independently check transactions for risks using tools for analysis and compliance with AML requirements.
Appendix 1. List of Prohibited Jurisdictions
The Service does not serve Users registered, residing, or located in the following countries and territories (the list may be updated):
American Samoa, Afghanistan, Bahamas, Botswana, Burma (Myanmar), Ethiopia, Crimea, Cuba, Canada, Republic of Ghana, Guam, Iran, Iraq, Yemen, Libya, Malaysia, Nigeria, Republic of Nicaragua, Singapore, North Korea (DPRK), Pakistan, Panama, Puerto Rico, Sri Lanka, Somalia, Saudi Arabia, United States of America (USA), Republic of South Sudan, Republic of Sudan, Syria, Republic of Trinidad and Tobago, Transnistria (Pridnestrovian Moldavian Republic), Tunisia, Virgin Islands, Bolivarian Republic of Venezuela, Republic of Artsakh.
