Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy

Digital asset exchange platform: Ychangers.com

Effective Date: January 3, 2026

Developed in accordance with international FATF standards and regulatory requirements of the countries where it operates

Introduction and scope

This document defines the measures implemented by the Ychangers.com platform (hereinafter referred to as the "Platform" or "Service") to prevent the use of its infrastructure for money laundering and terrorist financing. This policy is based on the recommendations of the Financial Action Task Force (FATF) and the laws of the jurisdictions where the Service operates.

The document"s primary objective is to minimize the risks of unauthorized use of the platform, ensure compliance with regulatory requirements, protect the Service"s reputation, and maintain the trust of customers and regulatory authorities.

Users who register and use Ychangers.com services automatically accept the terms of this Policy, which is an integral part of the User Agreement.

 

Platform Risk Management and Obligations Framework

Key commitments of Ychangers.com:

1. Implementation and compliance with KYC (Know Your Customer) and KYT (Know Your Transaction) procedures;
2. Conducting regular risk assessments related to clients and their transactions;
3. Continuous monitoring of transactions to identify suspicious patterns;
4. Suspension of operations and blocking of assets upon detection of signs of AML/CTF risks;
5. Submission of necessary information to authorized government agencies in cases provided for by law;
6. Ensuring the safety of personal data and transaction information for at least 5 years;
7. Organizing regular training for employees on AML/CTF compliance principles;
8. Guarantee of legality and compliance with international standards of assets transferred to users.

 

Requirements for outgoing cryptocurrency transfers:

All payments initiated by the Platform comply with the standards of international regulators (FATF, OFAC) and are carried out through:

- unique (one-time) crypto addresses;

- low-risk addresses according to specialized AML analytical systems and blockchain explorers;

- addresses of licensed crypto platforms.

 

User identification and verification procedures (KYC)

User verification procedure

The security system provides two levels of verification of client data:

1. Basic level - represents the standard identification procedure. To pass, you must provide:

• valid email address;
• identity document;
• documentary confirmation of registration address .

Application: Used for typical banking operations and low-risk areas.

2. Advanced level – initiated when increased risks are identified or the user has a high AML status. In addition to the basic level data, the service may request confirmation of the origin of the funds (Source of Funds).

Application: The decision on the need for an in-depth check is made by the security service on an individual basis, based on an assessment of the specific situation.

Confirmation of origin of funds (Source of Funds)

During the in-depth identification stage, the platform may request proof of asset legitimacy. The following categories of documents are accepted for verification:

• Income from employment and commerce: employment agreements, tax reporting, individual entrepreneur certificates.
• Movement of funds in accounts: bank statements recording replenishment.
• Capital income: dividend reports, property purchase and sale transactions.
• Gratuitous transfers: certificates of inheritance, deeds of gift.

The final list is compiled by the compliance service based on the client"s individual risk profile.

List of documents for verification

a) Identity document.

Requirements: validity, reliability of the source, full name, date of birth, photograph, and contact information. Accepted:

1. internal passport of a citizen of the country;
2. foreign passport;
3. driver"s license.

Important: documents are accepted only if they contain Latin transliteration of the data.

b) A document confirming the address of residence (not older than 3 months).

At the client"s choice:

1. A certified rental agreement or bank statement;
2. utility bills;
3. tax return;
4. other official documents with a current address for the last 90 days.

Important: documents are accepted only if they contain Latin transliteration of the data.

c) Selfie confirmation.

A photo of the customer holding a piece of paper with "Ychangers.com" and the current date written on it.

Additional provisions for verification

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

- Identity verification is performed on an ongoing basis; if a user"s activity is classified as "suspicious," the frequency of verification increases.

- The platform reserves the right to request updated documents at any time, even after successful verification.

- Users from jurisdictions included in the FATF, OFAC, EU, UN sanctions lists, as well as in Appendix No. 1, are not allowed to use the Service.

Processing times:

- Document verification: from 1 to 24 hours;

- Enhanced Due Diligence (EDD) procedure: from 24 to 72 hours.

 

Transaction monitoring and analysis (KYT procedure)

The platform uses a combination of automated and manual methods for analyzing cryptocurrency transactions, using solutions from leading providers (including AMLBot and similar systems).

Monitoring criteria:

1. Linking the sender/recipient address to sanctioned registries or “black” clusters (darknet marketplaces, fraudulent schemes, stolen funds, etc.);
2. Using mixers, tumblers or anonymization protocols (Tornado Cash and similar);
3. Identifying suspicious patterns:

- multiple small transactions (smurfing);

- abnormal volumes of transactions relative to historical behavior;

- transfers to newly created wallets;

- operations from high-risk jurisdictions;

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

 

Transaction scoring model (based on provider data):

Grade:	Risk range:
Low	The risk level does not exceed 62% according to the provider"s algorithm
Medium	The risk level is in the range of 63% to 74%
High	The risk level reaches 75% and higher

 

Note : The estimates provided 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 will be referred to a designated AML officer for manual review.

We recommend performing a preliminary AML check of the address using the service: https://www.bestchange.com/report/

 

Classification of clients by risk levels

Depending on the risk assessment, clients are divided into three categories with corresponding verification procedures:

Risk category	Procedures used	Frequency of rechecking
Low risk	Standard CDD (Customer Due Diligence) procedure	According to the standard schedule
Medium risk	Enhanced monitoring	At least once every 2 years
High risk	Enhanced Due Diligence (EDD) procedures:  • request for confirmation of source of funds;  • in-depth analysis of transaction history;  • annual update of KYC data.	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.

Suspicious Transaction Response Protocols

If signs of possible money laundering, terrorist financing, or other illegal activity are detected, the Platform takes the following measures:

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

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

Refund fee parameters 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 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.

 

Requirements for partners and contractors

Ychangers.com service:

1. Refuses to cooperate with platforms registered in jurisdictions with an insufficient level of 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.

Corporate compliance and staff training

 

1. A responsible AML officer has been appointed to oversee the implementation and updating of the Policy. Contact: support@ychangers.com;
2. All Platform 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 if necessary.

 

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 the appropriate clearance level;
4. Retained for at least 5 years after termination of the relationship with the client, unless legislation provides for a different period.

The privacy policy for the website is published separately.

 

Final and transitional provisions

The Platform reserves the right to unilaterally amend this Policy with mandatory notification to users via the official website. The most current version of this document is always available at Ychangers.com.

Contact for reporting suspicious activity: support@ychangers.com 

Responsible AML officer: support@ychangers.com

© Ychangers.com, 2026

Appendix No. 1

List of jurisdictions with a high level of AML risk (prohibited territories) :

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.