AML policy - ChangeCoins
Changecoins.io CHANGECOINS PAY LTD, in response to the concerns of regulators in many countries regarding the potential use of cryptocurrencies for money laundering, and recognizing that full anonymity in transactions contradicts the interests of its clients, adopts this Program on Combating Money Laundering and Terrorism Financing.
In this Anti-Money Laundering and Terrorism Financing Program, unless the context clearly indicates otherwise, the following terms shall have the meanings specified below:
- «Money Laundering» - giving a lawful appearance to the ownership, use, or disposal of funds or other property obtained as a result of a crime.
- «Service» - changecoins.io CHANGECOINS PAY LTD
- «Agreement» - the User Agreement, text available at the link https://changecoins.io/site/terms
- «User» - an individual who is legally competent under applicable law and has entered into an Agreement with the Service.
- «Program» - this Anti-Money Laundering and Terrorism Financing Program.
- «Public officials» - individuals holding government positions, and individuals holding positions in the civil service (including heads of state, government, ministers, heads of departments, central bank officials, senior judges, prosecutors, ambassadors, heads of state corporations and funds, members of parliaments).
- «Terrorism Financing» - the provision or collection of funds or the provision of financial services with the awareness that they are intended for financing the organization, preparation, and execution of a terrorist act.
All other terms and definitions found in the text of the Program shall be interpreted in accordance with the Agreement and the applicable laws of Ukraine.
In this Anti-Money Laundering and Terrorism Financing Program, unless the context clearly indicates otherwise, the following terms shall have the meanings specified below: The titles of the Program's sections (articles) are intended solely for convenience and have no legal significance.
The provisions of the Program are mandatory for the Service and Users.
The Service provides services to Users only under the condition that Users comply with the Program.
General Rule
The Service refuses any obligations to the User if it becomes aware that the User intends to use the Service in any way for illegal activities, including money laundering and terrorism financing.
Specific Cases
suspected or accused of engaging in terrorist or extremist activities or convicted of such actions;
subject to international or regional sanctions;
subject to or required to be subject to measures to freeze (block) funds and other property;
public officials found guilty of human rights violations;
citizens of states under international sanctions.
If there is a basis to suspect the User of illegal activities as per clause 3.1.1 of the Program, the Service reserves the right to terminate any actions in favor of such User at any time.
To complete a transaction exceeding 80,000 (eighty thousand) hryvnias, the User must provide documents to undergo the verification procedure according to Article 5 of the Program. A User conducting transactions not exceeding 80,000 (eighty thousand) hryvnias is not required to undergo the identification procedure according to Article 5 of the Program. For such unverified Users, the Service sets a maximum cumulative transaction limit of 80,000 (eighty thousand) hryvnias per month. If this cumulative transaction limit is exceeded, the User must undergo the identification procedure as per Article 5 of the Program.
The Service may block transactions until additional documents for identifying the beneficiary or beneficial owner, clarifications on the purpose of the transaction, and other circumstances (the necessary documents package is determined by the Service in each specific case) are provided by the User identified according to Article 5 of the Program, if:
the transaction conducted by the User equals or exceeds 600,000 (six hundred thousand) hryvnias;
the Service has reasons to consider the transaction conducted by the User as suspicious or unusual.
If the requested documents are not provided by the User, or the Service has doubts about the reliability of the information contained in these documents, the Service reserves the right not to process the transaction or to suspend the transaction until the appropriate documents are provided.
As an exception to clause 4.2 of the Program, the Service may require the User to provide documents according to clauses 4.2-4.3 of the Program when such User conducts a single transaction not exceeding 80,000 (eighty thousand) hryvnias or when the total sum of transactions does not exceed 80,000 (eighty thousand) hryvnias per month, if the Service has reasons to consider these transactions suspicious or unusual, and also in case of attempts to bypass the limits established in the Program through technical means or by colluding with other Users.
full name;
residential (registration) address;
date and place of birth;
details of identification documents.
The Service requires Users, who are foreign or Ukrainian public officials, or spouses or minor children of such officials, to inform the Service before conducting any transactions with the Service.
If the Service becomes aware that the User has concealed this information, the Service reserves the right to terminate any actions in favor of such Users.
Documents provided by the User to the Service according to clauses 4.2-4.3 of the Program must be in Ukrainian or Russian, and in the case of translated documents, such translation must be notarized.
Scanned copies of documents must be presented in high quality with a resolution of at least 300dpi.
Appoints an employee responsible for compliance with the Program, updating the Program, and its compliance with international standards and Ukrainian legislation requirements;
Establishes criteria for suspicious and unusual transactions, as well as methods for identifying suspicious and unusual transactions;
Analyzes transactions conducted by Users for compliance with criteria for suspicious and unusual transactions;
Keeps records of transactions conducted by Users and retains information about such transactions for 5 (five) years;
Checks at least once every 3 months for the presence among Users of individuals mentioned in clause 3.2 of the Program.
The Service has the right to unilaterally change the Program, including introducing new requirements and restrictions.
The Service will notify about the adoption of a new version of the Program by posting a news message on the website at the Internet address https://changecoins.io
The new version of the Program shall come into effect 3 (three) days after its publication on the Internet at the web address https://changecoins.io/site/aml
Users are obliged to familiarize themselves with the new version of the Program.
Continued use of the website https://changecoins.io will indicate Users' agreement with the conditions of the new version of the Program.
If the User does not agree with the conditions of the new version of the Program, they must stop using the Site and the System.