UnionXBit AML/KYC Policy

1. General Provisions

1.1. This AML/KYC Policy (the “Policy”) sets out how the UnionXBit exchange service (the “Service”) reviews transactions and verifies users to reduce the risks of money laundering, terrorist financing, fraud and other unlawful activity.

1.2. The Service applies verification measures taking into account the nature of a transaction, identified risks and applicable legal requirements.

1.3. By submitting an exchange order, the User confirms that they have read this Policy, are entitled to dispose of the funds involved and agree to the checks described in this Policy.

2. Definitions

• AML means measures to identify and reduce money laundering and terrorist financing risks.
• KYC means verification of the User’s identity, the information they provide and their control over the payment details used.
• User means a legally capable individual aged 18 or over, or a legal entity, using the Service.
• Funds means digital assets and money involved in an exchange transaction.
• High-risk assets means funds showing indicators of links to fraud, theft, ransomware, mixers, prohibited activities, sanctions restrictions or other material risks.
• Risk Score means a transaction risk assessment provided by an analysis tool used by the Service. The score is one factor in the review and does not rеplace consideration of the transaction’s circumstances.

3. KYC Procedures

3.1. The User must provide accurate information required to create and process an order. Depending on the circumstances, the Service may request documents or materials needed to verify identity, ownership or control of a payment method or wallet, and the source of funds.

3.2. Requests for additional information must be relevant to the purpose of the review. The Service will inform the User what information is required and how to provide it.

3.3. If suspicious activity is identified, the Service may suspend processing of the order while it conducts a review and notify the User where such notification is permitted.

3.4. The User must provide accurate and up-to-date information. The Service processes and retains information received in accordance with its Privacy Policy and applicable legal requirements.

4. AML Procedures

4.1. The Service may screen incoming digital assets and addresses associated with a transaction using specialised AML analysis tools. Automated results are considered together with other circumstances of the transaction.

4.2. Depending on the identified risk, the Service applies the following measures:

• Low risk: the order is processed in the ordinary course;
• Medium risk: additional checks or information about the User, payment or source of funds may be requested;
• High risk: processing is suspended pending review. Following the review, the Service decides whether to complete the order, decline the exchange or return the funds where a return is permitted.

4.3. Where indicators linking funds to unlawful activity are identified, the Service may suspend the transaction, request necessary information and take measures required by applicable law. Where there are grounds to do so, information may be provided to competent authorities.

4.4. The Service may refuse a transaction involving sources of funds, platforms or jurisdictions whose use is prohibited by applicable requirements or restricted under this Policy. If funds have already been received, the Service will consider a return following the necessary review and subject to any applicable restrictions.

4.5. An AML/KYC review does not, by itself, give rise to a fee payable by the User. If an exchange cannot be completed and the funds are returned, only actual and verifiable costs directly associated with the return may be deducted, in accordance with section 6.3 of this Policy.

4.6. If a transaction or return is temporarily restricted for reasons beyond the Service’s control, including restrictions imposed by a bank, payment systеm or platform used, the Service will inform the User of the order status and available next steps where notification is permitted. The Service will provide updates when circumstances change and resume consideration of the order.

5. Additional Identity Verification

5.1. If the information available is insufficient to establish the User’s identity or ownership of a payment, the Service may request additional evidence appropriate to the circumstances of the transaction.

5.2. Where necessary, the Service may request video verification using an identity document and evidence of control over the payment method or wallet. The Service will explain the requirements and how to submit the materials securely.

6. Return of Funds

6.1. Funds are returned after the checks necessary to establish ownership of the payment and the return recipient’s details. The information requested depends on the circumstances and identified risks.

6.2. Where no obstacle to a return exists, the Service will initiate it within 48 hours after receiving all required information and completing its review. The time it takes for the funds to arrive depends on the blockchain network, bank or payment systеm. If there is a delay, the Service will explain its cause and the next steps where such communication is permitted.

6.3. If an exchange order has not been completed, the Service will return the amount received less only actual and verifiable costs directly associated with the return, including applicable blockchain network, bank or payment systеm fees. No fee is charged for an AML/KYC review, handling a request or declining an exchange. At the User’s request, the Service will provide a breakdown of the return costs.

6.4. A return may be suspended where a binding restriction imposed by a competent authority, bank or payment systеm applies to the funds, or where ownership of the payment has not been established. The Service will resume consideration of the return once the obstacle has been removed.

6.5. The expiry of a period for the User to respond does not, by itself, end their right to request a return. To resume the review, the User must provide the order number and information needed to establish ownership of the payment.

7. Data Protection

7.1. Personal data and verification materials are processed in accordance with the Privacy Policy.

8. User Obligations

8.1. The User agrees to provide accurate information, comply with this Policy, use only funds they are entitled to dispose of and refrain from using the Service for unlawful activity.

9. Changes to This Policy

9.1. The current version of this Policy is published on the Website. Changes apply to orders created after the new version takes effect. The terms of an order already paid for will not be changed retroactively without the User’s consent, except where required by applicable law.

10. Transaction Self-Checks

10.1. Before sending funds, the User may check an address or transaction using AML analysis tools. A preliminary check does not guarantee that an order will be completed and does not rеplace the Service’s own review.

Appendix 1. Territories Restricted by the Service

The Service does not serve Users who are registered, reside or are located in the countries and territories listed below. This is the Service’s internal restriction list; inclusion does not, by itself, mean that a territory is subject to international sanctions. The Service must keep this list under review.

American Samoa, Afghanistan, the Bahamas, Botswana, Myanmar, Ethiopia, Crimea, Cuba, Canada, Ghana, Guam, Iran, Iraq, Yemen, Libya, Malaysia, Nigeria, Nicaragua, Singapore, North Korea, Pakistan, Panama, Puerto Rico, Sri Lanka, Somalia, Saudi Arabia, the United States, South Sudan, Sudan, Syria, Trinidad and Tobago, Transnistria, Tunisia, the Virgin Islands, Venezuela, Artsakh.