AML / KYC / SoF Policy

This AML / KYC / SoF Policy defines the principles and procedures applied by Ecash Expert for anti-money laundering (AML), counter-terrorism financing (CTF), customer identification (KYC) and source-of-funds verification (SoF).

Ecash Expert follows international AML/CTF standards including FATF (Financial Action Task Force) recommendations and applies a risk-based approach to AML checks.

The Policy is binding for all users without exception, regardless of amount, direction or payment instruments used.

Ecash Expert applies a risk-based approach and may suspend operations, request additional information, initiate KYC/SoF procedures, require video verification, refuse service and/or refund funds where provided by this Policy.

Each incoming and outgoing transaction is assigned a Risk Score based on blockchain analysis, AML/KYT results and source-of-funds categorisation (Risk Labels).

The Risk Score is computed from a combination of factors including transaction structure, source of funds, behavioural signals, transaction links and data from analytical and infrastructure services used by Ecash Expert.

Risk levels

In certain cases an operation may be temporarily suspended at risk levels 20–69 (medium) when transaction shows additional high-risk signals, including but not limited to:

• sanctions exposure — from 0.1%;
• links to darknet and fraud services — from 0.5–1%;
• use of mixers and anonymisation services — from 3–5%;
• tainted funds — from 5–10%;
• indirect links to high-risk addresses — from 15–20%;
• participation in illegal or unregulated services — from 1–5%;
• abnormal transaction activity or limit-circumvention attempts;
• inability to confirm source of funds (SoF);
• user refusal to pass KYC/verification;
• data inconsistencies;
• geographic and jurisdictional risks;
• matches with internal risk databases;
• AML system signals and additional analysis results.

Source of funds categories (Risk Labels)

Even minor exposure to critical-risk categories may suspend the operation regardless of overall Risk Score.

Final decision is based on combination of risk factors, not a single metric.

Ecash Expert may suspend the operation, request KYC and/or SoF until full resolution.

For analysing the origin of cryptocurrency funds, evaluating transaction links and detecting high-risk operations, Ecash Expert uses a combination of analytical, technical and infrastructure solutions.

In particular, Ecash Expert uses the GetBlock infrastructure to retrieve and process blockchain data needed for transaction, address and network activity analysis.

Additionally, internal and external analysis methods may be used to assess the risk of a specific operation, address, transaction chain or source of funds. Tools used can detect links to:

• sanctions lists and sanctioned jurisdictions;
• darknet markets and related services;
• fraud / scam services and schemes;
• stolen funds;
• mixers and anonymisation services;
• unlicensed or high-risk services;
• wallets, addresses and platforms hiding the origin of funds;
• other AML high-risk sources.

When Risk Score ≥ 70 or other elevated factors are detected, the user may be requested documents and information to pass KYC and/or SoF verification, including:

Verification time depends on case complexity, completeness of data and detected risks. Estimated timing:

• passport or ID card;
• selfie with the document;
• proof of residence (if required);
• Source of Funds confirmation;
• transaction history screenshots;
• explanation of the operation's economic purpose;
• other documents if needed.

• KYC — up to 24 hours;
• AML / SoF — from 72 hours to 10 business days.

Failure to provide documents, refusal of verification or knowingly false information may result in service refusal, suspension and refund decision under this Policy.

In high-risk cases Ecash Expert may initiate video verification as an additional measure for confirming user identity, legality of funds and actual control over wallets/payment instruments. Within video verification the user may be required to:

• state full name;
• state the current date;
• show an identity document;
• confirm purpose and nature of the operation;
• explain the origin of funds;
• show transaction history or other supporting evidence if needed.

If exchange cannot be completed, the user refuses verification, source of funds cannot be confirmed or other circumstances prevent completion, Ecash Expert may initiate a refund to the sender per this Policy and internal security procedures.

Refunds are processed after the necessary verification, provided refund does not contradict applicable law, AML/CTF rules and internal security requirements.

A refund is only possible once the user provides the data and documents required under the AML / KYC / SoF procedures (including, where necessary, identity documents, proof of ownership of the sending address or account, and proof of source of funds). Without such information, or where the user refuses to provide it, a refund may not be possible or may be delayed until the required information is obtained.

Ecash Expert does not accept funds with high or critical risk per AML/KYT analysis. Such operations are suspended pending additional verification including KYC and/or SoF.

Prohibited and high-risk sources include but are not limited to:

The list is non-exhaustive and may be updated based on blockchain analysis, internal risk criteria and data from infrastructure used by Ecash Expert including GetBlock.

• sanctioned addresses and jurisdictions on international sanctions lists;
• anonymisation/mixing services (incl. Tornado Cash, Blender.io and similar);
• darknet markets and related services;
• sources linked to fraud, stolen funds, extortion and other illegal activity;
• platforms with high risk or no proper KYC procedures;
• sources aimed at hiding origin of assets or circumventing AML/CTF.

Ecash Expert is not liable for funds from such sources and reserves the right to act per applicable law and AML/CTF requirements.

The list is non-exhaustive and may be updated based on blockchain analysis, internal risk criteria and data from infrastructure used by Ecash Expert including GetBlock.

Risk Categories

Ecash Expert is not liable for funds from such sources and reserves the right to act per applicable law and AML/CTF requirements.

The user may perform their own pre-AML check before sending using third-party services, including BestChange monitoring service.

Check via: https://www.bestchange.pro/report/

Pre-check results may be provided to Ecash Expert support for additional review and comparison with the internal Risk Score model.

Ecash Expert may temporarily suspend an operation upon detection of elevated AML risk, suspicious factors, need for additional verification or incomplete user data.

Funds may be held during verification, normally not more than 10 business days, unless a different timeframe is required by case nature, complexity, awaited user response or legal requirements.

On detection of illegal activity, suspicious transactions, possible terrorism financing, sanctions violations or other significant risks, Ecash Expert may share information with competent authorities and financial regulators per applicable law.

The user must use only their own payment instruments, wallets, accounts and details, unless explicitly agreed otherwise.

Using third-party accounts/cards/wallets may be considered a high-risk factor and result in suspension, additional document requests or service refusal.

Ecash Expert may request additional documents/information for AML/KYC/SoF verification when needed for risk assessment, source-of-funds confirmation, identity verification or operation legality.

Reasons may not be fully disclosed if disclosure could affect AML procedure effectiveness, create circumvention risk or contradict security requirements.

Ecash Expert may refuse to perform an operation in case of elevated AML risk, failure to provide requested data, inability to confirm source of funds, false information or other circumstances indicating elevated risk.

In such case the operation may be cancelled and funds returned to sender minus network fees, payment provider fees and other mandatory costs, if such refund is permitted under this Policy and applicable law.

User personal data is transmitted via secured channels and used solely for AML/KYC/SoF procedures, legal compliance, operation security and fraud prevention.

By providing documents and information under this Policy, the user consents to their processing to the extent necessary for these purposes.

Ecash Expert may update this Policy without prior notice when needed for legal compliance, security improvement or update of internal control procedures.

Use of the service implies user consent to this AML / KYC / SoF Policy.