AML Policy

This Policy establishes a set of rules and procedures aimed at preventing the laundering of proceeds obtained through unlawful activities, terrorist financing, as well as identifying customers and monitoring transactions. The application of this Policy is intended to protect ObmenoFF and its Users from potential involvement in unlawful activities. An AML check is mandatory for every Order. Where necessary, the User may independently verify in advance whether their cryptocurrency wallet complies with AML requirements before transferring funds by using the AML Checker. If the wallet address is unknown to the User, or the User is unable or refuses to undergo a preliminary AML check, and the aggregate AML risk level exceeds 60%, the exchange shall be suspended and the funds shall be refunded less the applicable network fee in accordance with the User Agreement.

1. Key Terms

ObmenoFF — an online platform designed for the exchange, purchase and sale of cryptocurrencies and other digital assets. User — an individual or legal entity using the ObmenoFF service. Cryptocurrency — a digital medium of exchange operating on blockchain technology. Electronic Currency — monetary funds circulating within electronic payment systems. Money Laundering — the process of giving an appearance of legitimacy to the possession, use or disposal of funds obtained through criminal activity. Terrorist Financing — the provision or collection of funds with the intention that they be used to commit terrorist acts.

2. Preliminary AML Check of a Cryptocurrency Wallet

Before creating an exchange Order, the User may independently verify the reliability of their cryptocurrency wallet using the AML Checker. To do so, the User must register on the website and purchase a package of checks in the Personal Account.

2.1. Registration on the Website

Creating an account is mandatory in order to use the AML Checker.
  • Click the “Registration” button in the upper-right corner of the website.
  • Provide the following information:
    • email address;
    • password.
  • Complete the registration by following the link sent to the specified email address.
After confirmation is completed, the User receives access to the Personal Account.

2.2. Purchasing an AML Check Package

AML checks are provided on a paid basis under a package-based system.
  1. Log in to the Personal Account.
  2. Click “Buy Checks”.
  3. Select the required package of checks.
  4. Click “Proceed to Payment”.
  5. The system will generate a deposit address. Send the payment to the specified address. Once the deposit has been successfully credited, the number of available checks will appear in the Personal Account and may immediately be used to perform AML checks on cryptocurrency wallets.

2.3. Performing an AML Check

  1. In the Personal Account, open the “AML Checks” section and click “New Check”.
  2. Enter the cryptocurrency wallet address from which the funds are intended to be sent.
  3. Select the applicable network: BTC, ETH, TRC-20, etc.
  4. Click “Check”. The system will deduct 1 check from the available package and provide the analysis result.

2.4. Providing the Result to an Operator

Once the AML check has been completed, the result is automatically sent by the system to the User’s email address. Further actions depend on the identified risk level:
  • If the risk level does not exceed 60%, the User may use the relevant wallet for an exchange without taking any additional action.
  • If the risk level exceeds 60%, the User must provide the check result to an operator via the website’s online chat.
The message must include:
  • the checked wallet address;
  • the date of the check;
  • a brief description of the obtained result.
The operator reviews the provided result and informs the User whether funds may be sent from the specified wallet. Important: notifications concerning an elevated risk level must not be ignored, as taking them into account is a mandatory requirement of the Service’s AML Policy.

3. Policy Objectives

  • Preventing the platform from being used for unlawful purposes.
  • Ensuring compliance with applicable laws and international standards.
  • Enhancing User security and maintaining the Company’s reputational resilience.

4. Policy Components

4.1. AML/CTF

  • Customer identification and verification of the source of funds.
  • Transaction monitoring for the purpose of detecting suspicious activity.

4.2. KYC

  • Collection and verification of customers’ personal and financial information.
  • Contact and personal information provided by the User when creating an Order must meet the requirements of completeness, accuracy and currency.
  • ObmenoFF ensures the protection, storage and processing of such data in accordance with the User Agreement and applicable law.
  • Users’ personal data is not transferred to third-party AML providers. Automated blockchain analytics tools may be used for transaction analysis; in such cases, only technical transaction data is processed, including cryptocurrency wallet addresses and transaction hashes, without transferring the User’s personal data.

4.3. KYT

  • Analysis of transactional activity to identify fraudulent or other unlawful transactions.
  • Suspension of suspicious transactions until information confirming their lawful nature is obtained.
  • Verification of the source of funds.

4.4. Handling High-Risk Transactions

The Service uses automated blockchain analysis systems that make it possible to identify signs of suspicious activity and transaction risk markers. As part of the review, transaction risk indicators are analyzed, including possible links to high-risk sources, fraudulent schemes, sanctioned services and other categories of suspicious activity. If an automated review determines that the aggregate risk level exceeds 60% and a connection is identified with high-risk sources listed in Section 4.5 of this Policy, the transaction may be temporarily suspended for additional review and for a decision to be made regarding the refund of funds to the User less the applicable network fee. If a decision is made to refund the funds, the relevant procedure may take up to 7 (seven) business days. The status of the transaction is determined on the basis of comprehensive automated analysis of transaction data and the results of AML/KYT checks.

4.5. Categories of High-Risk Sources

ObmenoFF reserves the right to block funds received from exchanges included on sanctions lists or classified as “high-risk”. At present, such platforms include: Black Sprut, BTC-e, Chiper Mixer, DuelBits, FreeBitcoin, Gandhiji.io, Hydra, NVSPC, Roobet, Tornado, WEX Exchange, Yolo Group, OMG!OMG!, Garantex, Commex, Tornado Cash, 1xBit, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, MEGA DARKNET MARKET, Primedice, Darknetone, Wasabi Wallet, DuckDice, Doubleway, Stake, Stolen Coins, Fraudulent Exchanges, Terrorism Financing, Bitzlato, Bitpapa.com, NetEx24.net, Trocador.app, Anonexch.io, Cryptomus, nobitex.ir, meer.kg, 1xbet, Aifory.pro, terminal.cash, SkyCrypto.net, FlashObmen.com, 60cek.net, hd-change.com, CoinBlinker.com, Metka.cc, AlfaBit.org, Heleket, payeer.com, Vexel, Fun Pay, Web Money, Freekassa, Yobit, exmo.com, exmo.me, Crypto Cloud, Cripta, BitBits, Nix Money, Bixter, freekassa.ru, kassa.cc, CoinStart, Prostocash, arvix.pro (abcex.io), heleket.com, xRocket.tg, CryptoCloud, weiss.bet, BTC-e / FinCEN, Sinbad, OFSI Huobi Global S.A. (HTX.com), as well as platforms from other sanctioned countries and services focused on anonymity and privacy. This list may be supplemented. Risk categories: Sanctions, Terrorism, Darknet, Ransomware/Malware, Mixing, Child Abuse, Stolen Funds, Scam/Fraud, Protocol Privacy, Bridge, Decentralized Exchange, Gambling. ObmenoFF shall not be liable for funds received from the above sources and reserves the right to provide relevant information to competent authorities.

4.6. Refund Procedure in the Event of an Unsuccessful AML Check

If an automated review determines that the aggregate risk level exceeds 60% and a connection is identified with high-risk sources specified in Section 4.5 of this Policy, the transaction may be temporarily suspended for additional review and for a decision to be made regarding the refund of funds to the User. If an AML block is applied:
  • up to 24 hours — to determine the final status of the review;
  • up to 7 (seven) business days from receipt of the wallet address — to process the refund;
  • in rare cases, funds may be held for up to 30 (thirty) business days where additional analysis, information from third parties, or completion of procedures by external AML providers or platforms involved in processing the transaction is required to complete the AML/KYT review.
Fees and expenses related to refunds The following amounts may be deducted from the funds subject to refund:
  • the actual blockchain network fee (Network fee);
  • documented expenses of AML, payment or other providers incurred in connection with the review, processing or unblocking of the transaction;
  • additional costs related to the refund — not exceeding 5% of the amount of blocked funds and in any event not exceeding the equivalent of USD 100.
Technical requirements for USDT refunds. To process a refund on the TRC-20, ERC-20 and BEP-20 networks, the address from which the funds were originally sent may need to hold the relevant native asset required to pay the network fee:
  • TRX — for the TRC-20 network;
  • ETH — for the ERC-20 network;
  • BNB — for the BEP-20 network.
The recommended available balance of the native asset for covering the network fee is the equivalent of 3–5 USDT. If the balance of the native asset is insufficient, the User may be asked to top up the relevant address in advance with the amount necessary to process the refund.

5. Rights and Obligations of the Service

ObmenoFF reserves the right to:
  • Suspend and block transactions.
  • Request additional documents and proof of identity from the User.
  • Require the User to complete video verification for identity confirmation purposes.
  • Provide relevant information to regulatory or law enforcement authorities.
  • Refund funds to the account from which the deposit was made and terminate further interaction with the customer.
  • If the User does not contact the Service for more than 6 (six) months with a request for the return of funds blocked as a result of AML checks performed by third parties, including centralized exchanges whose wallets are involved in processing the Order, ObmenoFF may independently determine the form of such refund: in USDT or in the relevant token, at the exchange rate applicable on the date the Order was created or at the exchange rate applicable on the refund date.

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