Service terms

This AML Policy (hereinafter — the Policy) governs Rexex's activities with respect to combating money laundering and the financing of terrorist activities.

The Rexex service warns users against attempting to use the service to legitimize funds obtained through criminal activity, to finance terrorism, to engage in any unlawful activities, or to use the service to purchase prohibited goods and services. The Rexex service administration has developed a set of measures to comply with national legislation and the requirements of the intergovernmental organization FATF (Financial Action Task Force).

The Rexex service adheres to the following rules:

1. Not to enter into business relationships with known criminals and/or terrorists;

2. Not to process transactions that are the result of known criminal and/or terrorist activities;

3. Not to facilitate any transactions associated with known criminal and/or terrorist activities;

4. Has the right to restrict or prohibit the use of all or part of the services, not to work with services and residents that are directly or indirectly associated with the following countries: Afghanistan, Bosnia and Herzegovina, USA, Democratic People's Republic of Korea, Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, Lao People's Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine, and others.

5. The Service does not work with funds associated with: BeriBit, HODLHODL, SkyBtcBanker, Black Sprut, Wasabi Wallet, Bitzlato, Hydra, Tornado Cash, OMG!OMG!, MEGA DARKNET MARKET, FreeBitcoin, casinos, gambling, 1xBet, Lazarus, OneCoin, Mirror Trading International (MTI), Bitconnect, PlusToken, Bitcoin Fog, Samourai Wallet, Silk Road, AlphaBay, Sheep Marketplace, fake ICOs, unlicensed cloud mining, pump-and-dump communities, phishing sites and crypto wallet clones, and others.

6. To refuse to enter into a business relationship without explanation.

Measures within the AML Policy compliance framework

1. Application of the KYC (Know Your Customer) Policy

To prevent unlawful transactions, the Service establishes certain requirements for all Orders created by the User and processed within the Service:

• The sender and recipient of the Payment under the Order must be the same person. The use of the Service's services strictly prohibits transfers to third parties.

• All contact details entered by the User in the Order, as well as any other personal data transferred by the User to the Service, must be current and completely accurate.

• The creation of Orders by the User using anonymous proxy servers or any other anonymous internet connections is strictly prohibited.

• The Service reserves the right not to disclose information about the methods and results of verification.

The list of documents required for verification is determined on a case-by-case basis.

If a transaction is blocked by the exchange due to high AML risk and the sender refuses to provide the necessary verification documents, the Rexex service bears no responsibility for the sender's funds.

2. Source of funds verification

The service administration may request:

• A bank statement for fiat funds.

• A video with wallet transaction details for cryptocurrencies.

• Complete information about the origin of fiat funds or cryptocurrency assets.

3. Actions in response to suspicious transactions

• Monitor transactions and report suspicious operations to law enforcement agencies.

• Request additional documents from the User.

• Suspend or terminate an account upon suspicion of illegal activity.

4. Blocking transactions with high AML risk

Rexex blocks transactions with an AML risk level above 10%, as determined on the basis of checks by the BitOK service, AML-bot, on the website bestchange in the address check section, or any other analytical services for identifying asset risk categories.

5. KYT (Know Your Transaction) Policy

The KYT policy is aimed at identifying the transaction counterparty when there are suspicions of Rexex being misused (e.g., laundering of digital currency or criminal origin of funds).

• Require information about the origin of the digital currency.

• Block the account and transfer data to law enforcement agencies.

• Require documents confirming identity and solvency.

• Refuse to withdraw funds to third-party accounts.

• Retain funds until the investigation is complete.

• Monitor the transaction chain.

• Refuse service when there are suspicions about the unlawful origin of assets.

6. AML Policy Compliance Officer

The responsibilities of the AML Policy Compliance Officer include ensuring compliance with the AML policy, namely:

• Collecting Users' identification information and transferring it to the responsible personal data processing agent;

• Creating and updating internal policies and procedures for drafting, reviewing, providing, and storing all reports required by existing laws and regulations;

• Monitoring transactions and analyzing any significant deviations from Users' normal activity;

• Implementing a records management system for storing and retrieving documents, files, forms, and logs;

• Regularly updating risk assessments.

• The AML Policy Compliance Officer has the right to cooperate with law enforcement agencies engaged in preventing money laundering, terrorist financing, and other illegal activities.

7. Additional measures

• Authenticity verification: The administration confirms the authenticity of documents through secondary sources.

• Data monitoring: Continuous monitoring of User activity, especially when identification information changes or suspicious activity occurs.

• Transaction monitoring: Control of all orders on the site, prohibition of third-party transactions through the User's account.

• Designation of a person responsible for AML policy compliance: A person who oversees Policy enforcement.

• Risk-based approach (RBA): Different levels of verification depending on the volume of transactions.

• Staff training: Training the team on Policy compliance requirements.

• Cooperation with authorities: Providing data upon request from law enforcement agencies or payment systems.

• Software security: Improvement of the IT department to protect against unauthorized access.

8. Risk assessment

The above list is not exhaustive.

The AML Policy Compliance Officer monitors User transactions on a daily basis to determine whether they should be reported and treated as suspicious.

9. Stages and timelines for conducting an AML check

User and transaction verification under AML/KYC/KYT procedures is carried out in several stages: Verification stages: • Initial automated transaction analysis using AML services — up to 1 hour; • If an elevated risk is detected — additional verification (KYT) — up to 24 hours; • Request for documents (KYC/SoF) if necessary — deadline for the User to provide them: up to 3 (three) calendar days; • Review of the provided documents — up to 3 (three) business days from the receipt of the complete package; • Decision on the transaction — up to 2 (two) business days after the verification is completed. The total verification period may be up to 7 (seven) business days, and in certain cases — up to 14 (fourteen) business days if additional analysis or a request for information from third parties is required. The Service reserves the right to extend the verification timelines in the presence of objective reasons.

10. Terms and timelines for refunds

A refund to the User is made in the following cases: inability to complete the transaction due to AML risks; the User's refusal to undergo verification; inability to confirm the source of funds. Refund conditions: refunds are made exclusively to the address/details from which the funds were received; refunds to third parties are prohibited; refunds are only possible after completing the necessary verification procedures (KYC/AML/SoF); the Service has the right to hold the funds until all checks are completed. Refund timelines: after a refund decision is made — up to 3 (three) business days; in certain cases, the timeline may be extended to up to 7 (seven) business days depending on network congestion or other technical factors.

11. Refund fee for AML cases

In the event of a refund of funds blocked during an AML check, the following conditions apply: The fee amounts to up to 5% of the refunded amount, but not more than 100 (one hundred) US dollars equivalent; The fee is withheld to cover expenses associated with processing the AML check and refunding the funds; Additionally, a network fee (blockchain fee) may be withheld. Exception: For bona fide Users who have completed KYC/SoF procedures and whose funds have not been confirmed to be linked to illegal activity: the refund or exchange fee is limited exclusively to the network fee; no additional fees are withheld by the Service. In accordance with international requirements, the Rexex Service applies a risk-based approach to combat money laundering and terrorist financing. Thus, measures to prevent money laundering and terrorist financing are proportionate to the identified risks.