Ex-money.net AML/CTF Policy

Platform: Ex-money.net

Effective Date: January 4, 2026

Standards: FATF Recommendations, national legislation of the countries of presence

 

1. Basic principles and objectives

This Policy defines the system of measures implemented by the Ex-money.net platform to prevent the use of the service for money laundering and terrorist financing. This document has been developed taking into account international standards of financial transparency and the regulatory requirements of applicable jurisdictions.

Key tasks:

- Reducing the risks of illegal use of the platform infrastructure;

- Ensuring compliance of activities with current legislation;

- Protection of the business reputation of the service and the interests of bona fide users;

- Maintaining trust from clients and regulatory authorities.

By registering on the platform, the user automatically accepts the terms of this Policy as part of the User Agreement.

 

2. Platform compliance obligations

Ex-money.net undertakes the following obligations:

Table 1. 

No.	Commitment:
1.	Implementation of customer identification (KYC) and transaction analysis (KYT) procedures
2.	Regular assessment of risks associated with users and their operations
3.	Continuous monitoring of transactions to identify suspicious patterns
4.	Suspension of operations and blocking of assets upon detection of AML/CTF threats
5.	Transfer of information to authorized bodies in cases provided by law
6.	Storage of personal data and transaction history for at least 5 years
7.	Regular training of staff on AML/CTF compliance standards
8.	Guarantee of legality and compliance with international standards of transferred assets

Requirements for outgoing crypto transfers:

All payments are made through:

- Unique (one-time) crypto addresses;

- Addresses with a low risk level according to AML analytical systems;

- Addresses of licensed crypto platforms.

 

3. User verification system (KYC)

3.1. Mandatory nature of the procedure

To access the platform"s full functionality and increase withdrawal limits, you must complete verification. Baksmany uses reliable partner solutions to protect your data.

3.2. Access levels and limits

The verification process consists of two stages:

Table 2

Basic level	Suitable for standard operations and individual banking areas.	E-mail; Photo of the document (passport/ID); Proof of residential address.
Advanced level	Required in cases of increased risk or when working with large sums.	All base level data; Information about the source of funds (Source of Funds).

 Important: The need for Level 2 is determined individually by the system. Requests for additional documents are only made if there are justified reasons related to the risk assessment.

3.3. What documents confirm the source of funds? (Source of Funds)?

To complete the enhanced security check, you may be required to verify the source of your funds. This is a standard procedure to ensure transparency of your transactions.

You can provide the following types of documents (the list is not exhaustive):

1. Work and business: contracts with employers, 2-NDFL certificates, tax returns, reporting for individual entrepreneurs.
2. Bank statements: documents from a bank that record the receipt of funds into an account.
3. Investments and property: contracts for the sale of real estate or vehicles, confirmation of dividend payments.
4. Other receipts: certificates of inheritance, gift agreements.

If you have documents confirming the legality of the funds, but they are not listed, you can upload them for review by the security service.

 

3.4. Required documents

A) Identity document (valid, with Latin transliteration):

- Internal passport of a citizen;

- International passport;

- Driver"s license.

B) Proof of residential address (not older than 90 days, with Latin transliteration):

- Lease agreement or bank statement;

- Utility bills;

- Tax return;

- Other official documents with the current address.

C) Selfie verification:

A photo of a user holding a piece of paper with "Ex-money.net" and the current date written on it.

3.5. Additional terms

- The platform conducts a cross-check of the data and reserves the right to refuse service if there are doubts about the veracity of the information;

- Verification is carried out on an ongoing basis; in case of suspicious activity, the frequency of checks increases;

- The platform may request document updates at any time;

- Users from FATF, OFAC, EU, UN sanctions jurisdictions, as well as from Appendix No. 1* - are not allowed to use the service.

3.6. Processing times:

- Standard check: 1–24 hours;

- Enhanced Due Diligence (EDD): 24–72 hours.

 

4. Transaction monitoring (KYT procedure)

The platform uses a combined approach to transaction analysis, using automated systems (including AMLBot and similar systems) and manual verification.

4.1. Analysis criteria

1. Linking addresses to sanctioned registries or “black” clusters (darknet, fraud, stolen funds);
2. Use of anonymization tools (mixers, tumblers, Tornado Cash and similar);
3. Identifying suspicious patterns:

- Multiple small transactions (smurfing);

- Anomalous volumes relative to historical behavior;

- Transfers to newly created wallets;

- Operations from high-risk jurisdictions;

1. Assigning each transaction a risk score: Low / Medium / High.

4.2. Risk scoring model

Table 3

Grade:	Risk range:
Low	Risk ≤ 62% according to the provider"s algorithm
Medium	The risk ranges from 62% to 72%
High	Risk ≥ 72%

Note : Estimates reflect the opinion of the analytics provider and may not fully correspond to the actual origin of the assets.

Transactions rated “High Risk” may be blocked and transferred to an AML officer for manual review.

A preliminary AML check of the address can be performed through the service: https://www.bestchange.com/report/

 

5. Classification of clients by risk level

Table 4

Category	Procedures used	Frequency of rechecking
Low risk	According to the standard schedule	Standard CDD procedure
Medium risk	Enhanced monitoring	At least once every 2 years
High risk	Enhanced Due Diligence (EDD): Request for confirmation of source of funds; In-depth analysis of transaction history; Annual KYC update.	Annual KYC update Annually

 

Automatic classification as high risk:

1. PEP (politically exposed persons, their family members and close associates);
2. Residents of countries from the FATF High-Risk Jurisdictions list;
3. Clients with an annual turnover exceeding the equivalent of USD 100,000.

 

6. Suspicious Activity Response Protocols

Whenever signs of potential money laundering, terrorist financing, or other illegal activity are detected, the platform takes the following steps:

1. Immediate suspension of a suspicious transaction;
2. Blocking the account until the completion of the internal investigation;
3. Formation of an internal suspicious transaction report (SAR/STR);
4. If there are grounds, inform the competent authorities (Rosfinmonitoring, FinCEN, EU FIU, etc.).

 

A client"s refusal to provide the requested information or failure to undergo verification is sufficient grounds for termination of service.

Refund fee for AML cases:

- Commission size: up to 5% of the blocked amount, but not more than $100 equivalent;

- Refunds will not be made if the assets are officially recognized as being related to illegal activities and are subject to seizure at the request of authorized bodies;

- For bona fide clients whose funds have not been identified as laundered after KYC/SoF procedures, the exchange or refund fee is limited solely to the blockchain network fee.

7. Requirements for partners and contractors

Ex-money.net platform:

1. Does not cooperate with platforms registered in jurisdictions with insufficient AML regulation;
2. Conducts due diligence of all partners (crypto exchanges, payment gateways, API providers);
3. Requires counterparties to have valid licenses and comply with international AML/CTF standards.

 

8. Corporate compliance and personnel development

1. A designated AML officer has been appointed to oversee the implementation and updating of the Policy. Contact : support@ex-money.net
2. All employees undergo mandatory training on AML/CTF issues at least once a year;
3. Internal audits of the compliance system are conducted quarterly; independent consultants are engaged when necessary.

 

9. Data protection and storage policy

All personal information and transaction data:

1. Encrypted using industry best security practices;
2. Stored on secure servers in jurisdictions that comply with the GDPR and MiCA regulations;
3. Available only to authorized personnel with appropriate clearance levels;
4. They are retained for at least 5 years after the termination of the relationship with the client, unless the law provides for a different period.

 

10. Policy Administration

The Platform reserves the right to unilaterally amend this Policy, subject to mandatory notification to users via the official website. The most current version of this document is always available on Ex-money.net.

Contact information for reporting suspicious activity: support@ex-money.net 

Responsible AML officer: support@ex-money.net

 

*Appendix No. 1

List of prohibited jurisdictions with high AML risk

Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma), as well as all territories included in the sanctions lists of FATF, OFAC, EU and UN on the date of the operation.

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© Ex-money.net, 2026