AML/KYC Policy
Anti-Money Laundering Policy.
IChangeOne warns users against attempting to use the service for money laundering, terrorist financing, illegal activities of any kind, as well as from using the service to purchase prohibited goods and services.
Money laundering is the concealment of an illegal source of funds by converting them into cash or investments that look legitimate.
General provisions
To prevent operations of an illegal nature, the Service establishes certain requirements for all Ads created by the User:
1. In the created Announcement, the Sender and the recipient of the Payment must be the same person. Transfers to third parties are strictly prohibited.
2. All contact details specified by the User in the Announcement, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely reliable.
3. It is strictly forbidden to create Advertisements by the User using anonymous proxy servers or any other anonymous connections to the Internet.
This Anti-Money Laundering Policy (hereinafter referred to as the “AML Policy”) describes the rules that IChangeOne adheres to:
1. do not do business with known criminals and/or terrorists;
2. not to process transactions that are the result of known criminal and/or terrorist activities;
3. not facilitate any transactions associated with known criminal and/or terrorist activities;
Verification Procedures
The IChangeOne service establishes its own verification procedures within the anti-money laundering standards – Know Your Customer (KYC) policy.
The IChangeOne service may request a verification procedure (providing an identity document, a passport or an identification card). IChangeOne reserves the right to collect Users’ identification information for the purposes of implementing the AML Policy. This information is processed and stored strictly in accordance with IChangeOne’s Privacy Policy and Personal Data Processing Policy.
Also, the IChangeOne Service may request a second document to identify the User: a bank statement or a utility bill not older than 3 months, which indicates the full name of the User and his actual place of residence, the service also has the right to request photo / video verification of the client, if there are suspicions in the dishonesty of the information provided.
IChangeOne verifies the authenticity of documents and information provided by Users and reserves the right to receive additional information about Users who have been identified as dangerous or suspicious.
If the User’s identification information has been changed or their activities appear suspicious, then IChangeOne has the right to request updated documents from the User, even if they have been authenticated in the past.
Responsible for AML Policy Compliance
The AML Policy Compliance Officer is a IChangeOne employee who is responsible for ensuring compliance with the AML Policy, as follows:
– collection of identification information of Users and its transfer to the responsible agent for the processing of personal data;
– creating and updating internal policies and procedures for writing, reviewing, submitting and storing all reports required by existing laws and regulations;
-monitoring of transactions and analysis of any significant deviations from the normal activities of Users;
– implementation of a records management systеm for storing and retrieving documents, files, forms and journals;
-Regularly updated risk assessment.
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.
KYT Policy
The KYT (Know Your Transaction) policy aims to identify the client of a transaction in the event of a use case where the Service has reasonable suspicion that the Client is using IChangeOne for other purposes.
Such a precedent may arise if the Service suspects the Client of illegal actions that can be qualified as laundering or attempted laundering of illegally obtained digital assets or the funds are of overtly criminal origin. For these purposes, the Service has the right to use any legal information, third-party tools for analyzing the origin of digital assets, as well as its own developments of the screening systеm.
In this case, the IChangeOne Service reserves the full right to:
Require the Client to provide additional information disclosing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
To block the account and any operations related to the Client, to transfer to the controlling financial activities and/or law enforcement agencies at the place of registration of the Service and, if necessary, at the address of the Client’s registration, all information and documents available on the incident;
Require from the Client documents confirming identity, physical existence, address of registration, solvency;
To return digital assets only to the details from which the transfer was made or switch to other details, after a full check by the Service’s security service, if it was possible to verify the legal origin of the Client’s funds;
Refuse the Client to withdraw funds to the account of third parties without explanation;
Hold the Client’s funds until the incident is fully investigated;
The Service reserves the right to monitor the entire chain of transactions in order to identify suspicious transactions;
The Service reserves the right to refuse to provide the Service to the Client if the Service has reasonable suspicions of the legitimacy of the origin of digital assets and to withhold funds on special accounts of the Service;
The Service reserves the right to refuse to provide the Service to the Client if the Service has reasonable suspicions of the legitimacy of the origin of digital assets and to hold funds on special accounts of the Service if it is impossible to track the entire chain of movement of digital assets from the moment they appear.
Conditions for making a refund of funds stopped for verification based on the results of the AML analysis of the transaction:
Refunds are made after a full check by the Service’s security service, which may inсlude detailed verification of the sender. Refunds are made minus a commission of up to 10% of the transaction amount to cover the labor costs for processing the application and arranging a refund.
The return, subject to approval by the Service, will be processed by the Service within 7 (seven) calendar days, starting from the date when the User was notified with the decision of the Service regarding his return request.
When making a refund, after passing the check (verification), the user must confirm the details to receive a refund.
