AML Policy

1. The Click-Change anti-money laundering, anti-terrorist financing policy (hereinafter the AML policy) and the “Know Your Customer” policy (hereinafter the “KYC Policy”) is designed to prevent and reduce the possible risks of participating in the Click-Change service. is in any illegal activity.
International laws and regulators, as well as the Fifth Anti-Money Laundering and Financing of Terrorism Directive (5AMLD) (https://ec.europa.eu/info/business-economy-euro/banking-and-finance/financial -supervision-and-risk-management/anti-money-laundering-and-countering-financing-terrorism_en#international), require the Click-Change service to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug trafficking and people, proliferation of weapons of mass destruction, corruption and bribery, as well as taking action in case of any form of suspicious activity and activity of its Users.

The exchange office, as a service provider of virtual/cryptocurrency assets, is obliged to check all suspicious transactions of virtual/cryptocurrency assets. During the verification, among other things, it is necessary to carry out user identification (KYC) and establish the origin of the virtual/cryptocurrency asset. Also, for the period of the transaction verification, the virtual/cryptocurrency asset must be kept on the balance sheet.

1.1 By creating an order on the site, the Client agrees that an AML / KYC check can be carried out in relation to him.

1.2 The AML / KYC verification procedure for clients and transactions is carried out by the AML officer of the Click-Change service, as well as by our liquidity provider.

1.3 As part of the AML / KYC verification, the Client agrees to the processing and storage of his personal data, as well as, if necessary, to the transfer of this data to the liquidity provider.

1.4 The AML/KYC procedure includes a set of developed measures.
- Implementation of continuous monitoring of transactions passing through the Click-Change service.
- Appointment of a responsible person (Money Laundering Reporting Officer)
- Risk-based approach
- Customer due diligence
- Improving the professional skills and knowledge of Click-Change service employees
- Interaction with state authorities in cases established by law.
- Bookkeeping, accounting, record keepin

1.5 To reduce the risk, the Click-Change service does not accept customers who reside in the following countries:
USA, Afghanistan, Albania, Angola, Algeria, Bangladesh, Barbados, Bolivia, Botswana, Burma (Myanmar), Burundi, Cambodia, Central African Republic, Chad, Congo, Conakry, Ivory Coast, Cuba, Democratic People's Republic of Korea ( North Korea), Ecuador, Egypt, Equatorial Guinea, Eritrea, Ghana, Guinea-Bissau, Haiti, Guyana, Iran, Iraq, Lao People's Democratic Republic, Lebanon, Libya, Mali, Morocco, Myanmar, Nepal, Nicaragua, North Macedonia, Pakistan , Panama, Somalia, South Sudan, Sudan, Syria, Tunisia, Uganda, Vanuatu, Venezuela, Yemen, Zimbabwe, Jamaica

2.1 If, based on the results of the analysis of AML-cryptocurrency assets, a risk above 40% is identified, or any label from the following is received:
DARK SERVICE
SCAM
STOLEN
MIXING(MIXER)
SEXTORTION
RANSOMWARE
HACK
PHISHING
TERRORISM FINANCING
FRAUD
BLACKLIST
STILL UNDER INVESTIGATION
CYBERCRIME ORGANIZATION
NARCOTICS
CHILD ABUSE
HUMAN TRAFFICKING,
SANCTIONS,
and other high-risk assets,
then the Client's transaction may be frozen indefinitely until complete identity verification (KYC).

2.2 Upon receipt of a service request from our liquidity provider, the Client's transaction may be frozen indefinitely until complete identity verification (KYC).

2.3 Upon receipt of a request from the competent authorities, the Client's transaction may be frozen for an indefinite period until complete identity verification (KYC).

2.4 If any suspicious activity is detected by the AML officer of the Click-Change service, the Client's transaction may be frozen indefinitely until complete identity verification (KYC).

3. Documents for KYC verification:
To confirm the origin of funds, we ask you to fully answer the following questions:
- through which platform did the funds come to you? Please provide screenshots of the sender's wallet/platform withdrawal history, as well as links to both transactions in the explorer;
- for what service you received funds;
- how much the transaction was, as well as the date and time of its execution;
- through which contact person did you communicate with the sender of funds? Please provide screenshots of the correspondence with the sender, where we can see the confirmation that the funds have been sent.

Also, please provide the following materials:
- Photo of one of the documents (passport, ID-card or driver's license).
- Selfie with this document and a sheet on which today's date and signature will be written by hand.

If necessary, the service has the right to request additionally any other documents not specified in this section.
All sent images (scans, photos, screenshots) must be in jpeg or png format.

3.1 The terms for consideration of documents for passing the KYC check for each case are individual and are not regulated in time.

3.2 The return of blocked assets is possible only upon passing the KYC verification.

3.3 User assets that have not passed AML verification are not subject to exchange.

3.4 Based on the results of a positive KYC check, the client will be refunded with a fee of 5%.

3.5 The return of assets is not possible if a request has been received for these assets from the competent authorities or an arrest/blocking of other agencies of any jurisdiction has been imposed (in this case, the blocked asset may be held as physical evidence).