This AML/KYC Policy (hereinafter – "Policy") describes the measures applied by the Exchange Cluster service (hereinafter – "the Service") to prevent the use of the platform for money laundering, terrorism financing, and other illegal activities.

The Service applies AML (Anti-Money Laundering) and KYC (Know Your Customer) procedures to reduce the possible risks of the Service being involved in any illegal activity.

By using the Service, the User confirms that:

• their funds are obtained legally;
• they do not use the Service for illegal operations;
• they agree with this Policy.

The sender and recipient of funds within an order must be the same person. Using the Service for transfers to third parties is prohibited.

All contact and personal data provided by the User must be current and accurate.

Using the Service through anonymous proxy servers, VPN, Tor, or other anonymization tools is prohibited.

It is prohibited to use the Service for:

• money laundering;
• terrorism financing;
• fraud;
• illegal gambling;
• purchase or sale of prohibited goods;
• use of stolen payment instruments;
• circumvention of sanctions restrictions.

The Service does not serve users or transactions associated with:

• darknet marketplaces;
• ransomware or malware operations;
• crypto mixers;
• other high-risk sources.

The Service, its administration, and owners are not liable for the misuse of the Service by third parties, actions of malicious actors, and any damages associated with the use of the Service.

The Service applies automatic AML verification of cryptocurrency transactions directly during order processing. The Risk Score assessment model is used to determine the risk level of crypto asset origin based on blockchain data.

Risk levels:

• Low Risk (0-25%) – low risk, standard processing;
• Medium Risk (25-50%) – moderate risk, possible suspension for additional verification;
• High Risk (50-100%) – high risk.

The Risk Score threshold is 50%. Transactions with a cumulative risk level exceeding this threshold are not subject to processing and will be returned to the sender minus the network fee.

The Service may use specialized blockchain analytics systems to analyze cryptocurrency transactions, including but not limited to:

• AMLBot;
• Crystal Blockchain;
• WhiteBIT AML.

The analysis results of these systems are used to assess transaction risk and make decisions regarding their execution.

For certain exchange directions, verification is a mandatory part of the order creation process. During order placement, the User receives a request to upload a photo or screenshot of the required verification unit directly on the order page.

Uploaded data is reviewed by the Service operator. The order cannot be confirmed without successful verification.

If an elevated transaction risk is detected, the Service may request additional documents to confirm the User's identity or source of funds, including:

• identity document (passport, ID card, driver's license);
• selfie or video with the document and order number;
• proof of source of funds (statements, screenshots);
• proof of ownership of the cryptocurrency wallet or payment instrument.

The Service reserves the right to request any additional documents if necessary.

If the User does not provide the requested documents within 30 calendar days from the date of the order creation, the Service reserves the right to return the funds (minus fees) or escalate the information to competent authorities.

The standard verification period is up to 24 hours.

In cases requiring additional analysis, the verification period may be extended up to 72 hours.

The User is obligated to provide requested documents within a reasonable timeframe.

The Service has the right to suspend transaction execution in cases of:

• elevated Risk Score;
• suspicion of illegal origin of funds;
• lack of necessary information from the User;
• violation of this Policy.

In such cases, funds may be temporarily held until the verification is completed.

If an operation is rejected, funds may be returned to the User at the sender's address.

Returns are processed after the completion of AML/KYC verification procedures.

The return fee may be up to 5% of the transaction amount, but no more than 100 USD equivalent.

For good-faith users whose funds are not confirmed to be associated with illegal activity, only the blockchain network fee is retained.

The Service may share information about transactions and users with:

• law enforcement agencies upon official request in accordance with applicable law;
• payment systems;
• AML analytics services.

Disclosure of information to government and law enforcement agencies in cases prescribed by law does not constitute a breach of confidentiality obligations.

The Service guarantees the confidentiality of User data in accordance with the Privacy Policy.

Information about transactions and verifications may be stored by the Service for up to 5 years to comply with AML control requirements and prevent financial crimes.

The Service reserves the right to modify this Policy without prior notice. The current version of the Policy is always available on the Service's website.

By performing an exchange, the User agrees to all terms of this Policy and undertakes to comply with them.