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AML policy

Money laundering refers to actions aimed at turning money or other tangible assets obtained from illegal activities (terrorism, drug trafficking, illegal arms trade, corruption, human trafficking, etc.) into money and assets that have a legal status. Such actions are taken to make it impossible to trace the criminal or illegal origin of money.

The aim of anti-money laundering is to ensure that clients involved in financial transactions involving the OpenChange site are identified to a reasonable standard, with a minimum set of identification data for law-abiding clients. In accordance with the requirements of international law, the OpenChange Company has developed an internal policy to combat the financing of terrorism and the legalization of proceeds from crime. OpenChange carefully monitors suspicious activities and transactions and promptly reports such activities to the appropriate authorities.

AML and KYC verification
1) Each incoming transaction is checked using the AMLBot system, as well as internal tools of partner custodial services.
2) During the transaction check, the following criteria are assessed:
- The presence of high-risk indicators (including association with illegal activity, fraud, etc.);
- The origin of funds and their possible inclusion in sanctions lists;
- Signs of splitting amounts during exchange transactions both within the Service and in other exchangers;
- Other factors that are not disclosed in order to maintain the effectiveness of the monitoring system.
3) If the Service operator or the AML department of the custodial service through which the deposit was made identifies the transaction as high-risk:
- Order processing is temporarily suspended;
- The user receives a request to carry out the identity verification procedure and provide confirmation of the legality of the origin of the funds.
4) The User undertakes to provide the requested photo/video materials, wait for the verification decision and not make any claims against the Service.
5) If verification is not passed, the order will not be cancelled and funds will not be returned.
6) If verification is successful, the funds will be returned to the client to the agreed address minus the transaction sending fee and the Service operation fee of 1% of the order amount (min. 40 USD, max. 100 USD).

In its activities, OpenChange cooperates with cryptocurrency exchanges, to which funds sent by Users are credited. If the security service of the exchange receives a request from law enforcement agencies to provide information about the User, OpenChange reserves the right to transfer all data about the User:
- personally to law enforcement agencies
- through the security service of the cryptocurrency exchange
- via AML officer

The following services are prohibited for payment of orders and for receiving payments on orders:
- any Russian payment and crypto services
- any services aimed at anonymity and privacy (trocador.app, anonexch.io, etc.)
- Garantex, Tornado Cash, Hydra, Blender, Lazarus Group, Genesis Market, ChipMixer, Shinbad, as well as any Iranian platforms and other platforms of prohibited/sanctioned countries.
Splitting funds into parts and exchanging more than two orders is prohibited, regardless of which exchange office executes these orders. If splitting of funds is detected, the custodian service may suspend the execution of the order and require verification of the sender's identity.

OpenChange reserves the right to refuse a transaction at any stage if, in the company's opinion, the transaction is related in any way to money laundering or criminal activity. In accordance with international law, OpenChange is not required to inform the Client that its activities have been reported to the relevant authorities as suspicious.

OpenChange is constantly updating the electronic system for verifying transactions and customer identification data in accordance with all current legal regulations, and also organizes trainings for its employees regarding the fight against money laundering.

Acceptable values of risk categories:
  • Darknet Marketplace or Darknet Service - 0%
  • Illegal Service - 0%
  • Gambling - 0%
  • Drugs - 0%
  • Child Abuse - 0%
  • Stolen Coins or Credit Cards - 0%
  • Ransom - 0%
  • Malware (excluding Ransom) - 0%
  • Blackmail - 0%
  • Terrorism - 0%
  • Illegal migration - 0%
  • Human trafficking - 0%
  • Smuggling - 0%
  • Enforcement Action - 0%
  • High Risk country and Sanction country - 0%
  • Fake documents, fake document rendering - 0%
  • Illegal weapons - 0%
  • Politically exposed person, corruption - 0%
  • DDOS service - 0%
  • Phishing service - 0%
  • Scam - <5%
  • Scam ICO - 0%
  • State bodies - 0%
  • Personal data US or EU - 0%
  • Personal data RU or CIS - <10%
  • Personal data other - <10%
  • Precursors - <10%
  • China precursors manufacturing - <10%
  • Stolen DataBase - <10%
  • Paramilitary organization - <10%
  • Cracked software - <10%
  • Laundering of money - <10%
  • Illegal financial transactions - <10%
  • Bribge - <25%
  • Mixing Service - <25%
  • Online Marketplace - <25%
  • OTC Exchange With High ML Risk - <50%
  • OTC Exchange With Very High ML Risk - <50%
  • Exchange With High ML Risk - <50%
  • Exchange With Very High ML Risk - <50%
  • Fraudulent Exchange - 0%
  • DEX (excluding Bridges) - <50%
  • P2P Exchange With High ML Risk - <50%
  • P2P Exchange With Very High ML Risk - <50%
  • ATM - <50%