KYC/AML Policy

AML POLICY OF

Last updated: November 12, 2025

This AML/CTF policy governs the procedures for customer identification and verification (KYC) in accordance with the requirements of the law and international standards, transaction monitoring, and the application of measures to prevent the use of the Service for money laundering, terrorism financing, and other unlawful activities.

1. Definitions

KYC (Know Your Customer) — procedures aimed at identifying and verifying the identity of customers.

AML/CFT (anti-money laundering and combating the financing of terrorism) — procedures aimed at preventing and detecting the legalization of proceeds obtained through criminal means and the financing of terrorism.

Dark Market — an online platform specializing in the sale of illegal goods or services.

Sanctions — restrictions or prohibitions imposed by international organizations and governments on countries, legal entities, or individuals in connection with violations of international law or standards.

Stolen Coins — cryptocurrency units obtained through theft or fraud and/or included in sanctions lists or lists of objects of criminal investigation.

Scam — a deceptive scheme leading to the loss of monetary funds or other valuable resources.

High-risk transaction — a transaction whose features indicate an elevated risk of money laundering or terrorism financing.

2. User Identity Verification (KYC)

2.1. The User undertakes to complete identity verification at the request of the Company and in accordance with its requirements. The Company may request additional documents for identity verification or for a particular transaction.

2.2. The verification procedure may include (but is not limited to):

• an identification document (passport, international passport, ID card, driver's license, etc.);
• a selfie to confirm identity;
• additional information required for full verification in accordance with international KYC standards.

3. Verification Procedures

3.1. The Company has developed a system for identifying high-risk transactions and other unlawful activity. The Company has the right to freeze funds until the necessary information is provided and the checks are completed.

3.2. The Company carries out continuous monitoring of all user transactions to detect anomalous or suspicious operations. For these purposes, the service crystalintelligence.com and/or other reputable analytical resources are used.

3.3. If the established AML risk threshold is exceeded, the Company reserves the right to:

• suspend the transaction or freeze funds until the investigation is completed;
• request from the user a photo or video with a document confirming identity;
• request screenshots or videos from the crypto wallet account;
• request other materials and documents related to the transaction;
• refuse to withdraw funds to third-party accounts without explanation.

If the requested information is not provided or there is no response within 3 months, the funds may remain frozen. Funds frozen due to sanctions may remain blocked until the sanctions are lifted.

4. Restricted Territories and Sanctions

The Company does not provide services to persons located in or associated with the territories of the following states and regions: the Republic of Abkhazia, the Republic of South Ossetia, the Nagorno-Karabakh Republic, the Turkish Republic of Northern Cyprus, the Pridnestrovian Moldavian Republic, as well as territories temporarily not controlled by the Government of Ukraine.

In addition, the Company does not provide services to persons included in the sanctions lists of the UN, the European Union, His Majesty's Treasury of the United Kingdom, and OFAC.

5. Reporting of Suspicious Transactions

Employees continuously monitor transactions and the behavior of Users for signs of suspicious operations. If such operations are detected, employees of the Company immediately notify management and submit a report to the competent regulatory or law enforcement authorities.

6. Freezing and Completion of Operations

The Company reserves the right to temporarily suspend or freeze the User's operations and funds if elevated risk, suspicious transactions, or inconsistencies in the data provided are detected.

The refund of funds or completion of an exchange operation is carried out only after successful verification of the User's identity, confirmation of the authenticity of all documents and information, and successful completion of an internal review.

7. Data Storage

All documents and data provided by Users, including the results of completed verification, are stored for at least five (5) years after the end of the relationship with the User.

8. Changes to the Policy

The Company reserves the right to amend this AML/CTF policy at any time. The updated version of the policy is published on the Service's website. By continuing to use the Service after the changes are published, the User confirms acceptance of the updated terms.