AML Policy

changecoins.io, being an agent of Grizzly Techland OU, in accordance with the regulators' concerns about the possibility of using cryptocurrencies to legalize the proceeds of crime, and recognizing the complete anonymity of cryptocurrency operations contrary to the interests of their customers, adopts this Program in the field of combating money laundering and terrorism financing on the following.

1. Terms and Definitions

1.1. In the AML Policy, unless the text expressly states otherwise, the following terms will have the meanings indicated below:

-"Legalization of crime proceeds"- giving a lawful type of possession,use or disposal of funds or other property obtained as a result of a crime.

- “Service” - changecoins.io

- “Agreement” - the User Agreement, the text of which is available at https://changecoins.io/site/terms

- “User” is a sui iuris individual in accordance with applicable law who has entered into an Agreement with the Service.

- “Program” - this AML program.

- “Public Officials” - persons holding public positions and persons replacing civil service positions (including heads of state, governments, ministers, heads of departments, heads of central banks, judges of high courts, prosecutors, ambassadors, heads of state corporations and foundations, members of parliament).

- “Terrorism financing” - providing or raising funds or providing financial services with the knowledge that they are intended to finance the organization, preparation and commission of a terrorist act."

1.2. All other terms and definitions found in the text of the Program should be interpreted in accordance with the Agreement and current legislation of Ukraine.

1.3. The titles of articles of the Program are intended solely for the convenience of using the text of the Program and have no literal legal meaning.

2. Program applicability

2.1. The provisions of the Program are mandatory for the Service and Users.

2.2. The Service provides services to Users only on the terms of Users' compliance with the Program.

3. Refusal to cooperate

3.1. General rule

3.1.1. The Service disclaims any obligations to the User if the Service becomes aware that the User seeks to use the Service in any way for carrying out illegal activities, including legalization of crime proceeds and terrorism financing.

3.2. Special cases

The Service disclaims any obligations to the User if it requires the commission of any actions in favor of the persons:

3.2.1. suspected or accused of terrorist activity or extremist activity or convicted for these actions;

3.2.2. in respect of whom international or regional sanctions are adopted;

3.2.3. in respect of whom measures are applied or must be applied for freezing (blocking) of money and other property;

3.2.4. who are public officials found guilty of violating human rights;

3.2.5. who are nationals of states that are subject to international sanctions.

4. Operation restrictions

4.1. If there is a reason to suspect the User in carrying out illegal activities in accordance with clause 3.1.1 of the Program, the Service reserves the right at any time to stop making any actions in favor of such User.

4.2. To make a transaction that exceeds 80,000 (eighty thousand) hryvnia, the user is obliged to undertake the verification in accordance with the Article 5 of the Program.

A user performing operations for an amount not exceeding 80,000 (eighty thousand) hryvnas has the right not to go through the identification procedure in accordance with the provisions of Article 5 of the Program.

For such unidentified Users, the Service establishes the maximum total cost of operations in the amount of 80,000 (eighty thousand) hryvnia per month.

In case of exceeding the total value of transactions the user must undergo the identification procedure in accordance with the provisions of Article 5 of the Program

4.3. The Service has the right to suspend the operations of a User until the User provides the

additional documents to identify the beneficial owner, source of funds proof and other required documents

 (the package of necessary documents is determined by the Service in each specific case), if:

4.3.1. User's operation is equal to or exceeds 600,000 (six hundred thousand) hryvnias;

4.3.2. the Service has a reason to consider the operation conducted by the User doubtful or unusual.

4.4. If the requested documents were not provided by the User, or the Service had doubts about the accuracy of the information contained in these documents, the Service reserves the right not to carry out the operation or suspend the operation until the relevant documents are provided.

4.5. As an exception to clause 4.2 of the Program, the Service has the right to require the User to provide documents in accordance with clauses 4.2-4.3 of the Program, when such User performs a one-time operation for an amount not exceeding 80,000 (eighty thousand),

 or when performing transactions, the total amount of which does not exceed 80,000 (eighty thousand) hryvnia per month, if the Service has grounds to consider these operations as doubtful or unusual operations, as well as in the event of attempts to circumvent the restrictions established in the Program, by technical means or in collusion with other Users.

5. User Identification

5.1. To identify the User, the Service verifies the following information about the User:

5.1.1. full name;

5.1.2. address of residence (registration);

5.1.3. date and place of birth;

5.1.4. details of identity documents.

5.2. User identification occurs upon presentation of a scanned copy / photo of a passport or other identity document and a copy / photo of a document confirming the place of residence.

If necessary, the Service may require the User to provide other documents necessary to comply with the requirements of the Program.

5.3. The Service requires Users who are foreign or Ukrainian public officials, or spouses or minor children of such persons, to inform the Service of this before commencing any operations with the Service.

In the event that the Service becomes aware that the User has hidden this information, the Service has the right to terminate any actions in favor of such Users.

6. Documents requirements

6.1. Documents provided by the User to the Service in accordance with clauses 4.2-4.3 of the Program must be written in Ukrainian or Russian, and in case the documents are translated, such translation must be notarized.

6.2. Scanned copies of documents must be submitted in high quality with a resolution of at least 300dpi.

7. Measures taken by the Service

To ensure compliance with Clause 2.1 of the Program, the Service takes the following measures:

7.1. Appoints an employee responsible for compliance with the Program, updating the Program and its compliance with international standards and the requirements of Ukrainian legislation;

7.2. Establishes criteria for suspicious and unusual transactions, as well as methods for determining suspicious and unusual transactions;

7.3. Analyzes the operations conducted by users in terms of their compliance with the criteria for suspicious and unusual transactions;

7.4. Keeps records of operations conducted by Users and saves information on such operations for 5 (five) years;

7.5. Checks, at least once every 3 months, the presence among the Users of the persons specified in clause 3.2 of the Program.

8. Changes to the Program

8.1. The Service has the right to unilaterally change the Program, including the addition new requirements and restrictions.

The Service announces the acceptance of a new version of the Program by posting a message on a website at http://changecoins.io

In this case, the new version of the Program comes into force upon expiration of 3 (three) days from the moment of its posting on the Internet at the network address http://changecoins.io/aml

8.2. Users agree to get acquainted with the new version of the Program.

 Continued use of the site http://changecoins.io will mean that the Users agree to the terms of the new version of the Program.

8.3. If the User does not agree with the terms of the new version of the Program, he/she ceases to use the Site and the System.