AML/KYC

1. Introduction

The anti-money laundering and “Know Your Client” (hereinafter — «AML / KYC Policy») policy is designed to prevent and reduce the possible risks of AvanChange being involved in any illegal activities.

2. The purpose of internal regulation

AvanChange service adheres to anti-money laundering and anti-terrorist financing (AML) practices and measures. The purpose of these measures is to demonstrate that AvanChange takes any attempt to use its service for illegal purposes seriously.

3. Caution

AvanChange service warns users against attempts to use AvanChange service for money laundering, terrorism financing, fraud of any kind, as well as against using the service for purchasing prohibited goods and services.

AvanChange service, its administration, employees and domain owners are not responsible for misuse of the AvanChange service by third parties, malefactors and possible damages related to the use of AvanChange service.

4. Requirements

To prevent transactions of an illegal nature, AvanChange service sets certain requirements for all Applications created by the User:

4.1. The sender and the recipient of the Payment on the Application must be the same person. Transfers in favor of third parties using the Service are strictly prohibited.

4.2. All the contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service must be current and fully accurate.

4.3. It is strictly forbidden to create Applications by the User using anonymous proxy-servers, VPN, Tor or any other anonymous Internet connections.

5. Verification procedures

One of the international standards for the prevention of illegal activities is customer due diligence (hereinafter – Verification). To this end, AvanChange implements its own verification procedures in strict anti-money laundering standards and a procedure «Know Your Client».

5.1. The AvanChange Service may require the User to provide the AvanChange Service with reliable, independent source documents, data or information (e.g., national ID card, international passport, bank statement). For such purposes, the AvanChange Service reserves the right to collect User identification information for purposes of compliance with the AML/KYC Policy.

5.2. AvanChange Service will take steps to verify the authenticity of documents and information provided by Users. All legal methods to double check identifying information will be used, and the AvanChange Service reserves the right to investigate cases of certain Users whose identities have been determined to be dangerous or suspicious.

5.3. AvanChange Service reserves the right to verify the User's identity on an ongoing basis, especially when his/her identification information has been changed or his/her activity seems suspicious (unusual for a particular User). In addition, AvanChange Service reserves the right to ask Users for up-to-date documents, even if they have been authenticated in the past.

5.4. User identification information will be collected, stored, shared and protected strictly in accordance with the AvanChange Service Privacy Policy and related policies.

5.5. After confirmation of the User's identity, AvanChange Service may refuse to provide services to the User in a situation where the AvanChange Service is used to conduct illegal activities.

5.6. Users who intend to use payment cards for the purpose of consuming services must complete card verification according to the instructions available at AvanChange.com

5.7. AvanChange Service has regulatory requirements to verify the source of funds or cryptocurrency to know that the sources of funds that Users use to trade are legitimate.

6. Responsible officer

The AML Compliance Officer is the person duly authorized by the AvanChange Service whose responsibility it is to ensure that AML/KYC policies are effectively implemented and enforced.

6.1. It is the responsibility of such officer to oversee all aspects of AvanChange's anti-money laundering activities, including money laundering and terrorist financing, including but not limited to the following methods: collection of user identification information;

  • Create and update internal policies and procedures for completing, reviewing, submitting and maintaining all reports and records required by applicable laws and regulations;
  • monitoring transactions and investigating any significant deviations from normal activity;
  • implementation of a records management system for proper storage and retrieval of documents, files, forms and journals;
  • regular updating of the risk assessment;
  • Providing law enforcement agencies with the information they need under applicable laws and regulations.

6.2 The AML Compliance Officer has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.

7. System functions

The AvanChange service performs many compliance-related tasks, including data collection, filtering, record keeping, investigation management and reporting. System functions include:

  • Checking Users daily for the existence of recognized «blacklists» (e.g. OFAC), aggregating transmissions across multiple data points, placing Users on watch and denial of service lists, opening cases for investigation where appropriate, sending internal communications and completing mandatory reports, if applicable;
  • case and document management.

8. Behavior Analysisя

AvanChange Service verifies Users not only by checking their identity, but more importantly, by analyzing their behavior in transactions. Therefore, AvanChange Service relies on data analysis as a risk assessment and suspicion detection tool.

9. Risk scoresв

AvanChange, in line with international requirements, applies risk assessment practices to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, AvanChange ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified.

10. Performing customer checks

If the Administration of AvanChange Service reasonably suspects that the User is attempting to use the Service for money laundering or any other illegal activity, the Administration has the right to do so:

  • suspend the user's exchange operation;
  • ask the User for documents identifying him/herself;
  • Request any additional information and documents from the User in case of suspicious transactions;
  • Ensure that reports of the suspicious nature of transactions are relayed to appropriate law enforcement agencies through the AML compliance officer.

11. Privacy

AvanChange service guarantees customer privacy in accordance with the privacy policy of the service.

11.1 The AvanChange Service and its employees are obliged to maintain confidentiality regarding any facts revealed in connection with any questionable transaction. This obligation also applies to users of the Service and to third parties to whom information on the transaction has been transmitted.

11.2 The obligation of confidentiality imposed on AvanChange Service employees shall survive the termination of their employment or any other contractual relationship with AvanChange Service or the transfer of such employees to another workplace. Disclosure of such information to governmental, law enforcement or other entities as permitted by law does not constitute a breach of the obligation of confidentiality.

11.3. The obligation of confidentiality, provided that the use of disclosed information is limited to preventing the legitimization of proceeds of crime and terrorist financing, may not apply to disclosures between financial institutions that form a consolidated group that cooperates with the AvanChange Service.

12. Conclusion

Therefore, AvanChange Service shall not be held legally responsible for its use for money laundering, terrorist financing or prohibited goods and services purchase purposes, but shall take all possible and available actions to prevent any attempts to use the AvanChange Service for money laundering, terrorist financing or prohibited goods and services purchase purposes.

By making the exchange, the User agrees to point 13.5. of AvanChange terms agrees to all of the terms of these policies and agrees to abide by them.

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