AML Policy
This Anti-Money Laundering Policy (hereinafter referred to as "AML Policy", or "Policy") outlines the provisions and predefined procedures after which The Change (hereinafter referred to as "The Change", "we", "Us", "Our", or, "Service") is preventing any illegal activity from occurring and ensuring compliance with all applicable laws and regulations related to AML/KYC (referring to "Anti-Money Laundering" and "Know Your Customer" respectively).
1. AML Measures
We strive to promote security for our partners and clients by actively protecting them from any fraudulent activity and we remain committed to organized efforts aimed at ensuring the highest levels of financial integrity. In this direction, our team has developed a comprehensive and cutting-edge framework of AML Systems and Procedures, collectively referred to as AML Measures.
1.1 AML System
If a transaction receives a high score in our risk framework, it is placed on hold and an action request is triggered. The customer whose transaction is on hold is prompted to create an account (if they exchanged as a guest) and validate it through basic KYC verification so that the transaction can be processed.
1.2 AML Procedures
Our AML Procedures encompass a series of actions designed to verify the legitimacy of funds and ensure that the client responsible for them adheres to all legal compliance requirements in accordance with applicable laws and our TOS (Terms of Service). Depending on the specific circumstances, when the risk score of a transaction exceeds any of the predefined thresholds, our system puts the transaction on hold and any of the following actions may be triggered: KYC verification requirements, SOF (Source Of Funds) inquiries, manual case reviews, transaction freezing, transaction reporting, and account restrictions among others that may be conducted per case.
2. Acceptance Warranty
By using our Services, each user warrants the acceptance and agreement with the AML Procedures, which may be applied. As part of such procedures The Change and our partnered mediating exchange service providers, if any, may request information and documents, aiming, but not limited to, identifying the client, proving the source of the funds, and ascertaining the user’s compliance with our TOS, our partner’s TOS if any, along with any applicable law.
We reserve the right to conduct AML Procedures on an ongoing basis, proactively in case of any occurrence such as a change in the identification documents, and especially when the user activity is considered suspicious or high-risk. A user activity may be deemed suspicious through our AML System and/or at our sole discretion. We reserve the right to request up-to-date documents from any user, even if they have successfully passed an AML Procedure in the past.
During the AML Procedure enforcement, users may be requested to provide us with the following:
- A high-quality photo of their ID and/or passport, valid in their country;
- A high-quality photo of the user to evaluate if it matches the document provided in the previous step;
- Liveness checks, which involve issuing random instructions to ensure that the KYC process is conducted in real time and in accordance with our request;
- Source of Funds and any other applicable documentation that may be deemed necessary to ascertain that the funds originate from legal sources and the user’s compliance with our TOS (Terms of Service) and applicable laws.
3. Evaluation Process
3.1. Conducting Evaluation
The Change reserves the right to appoint third-party service providers certified in relevant procedures, for the purpose of documentation reviewing, ascertaining the authenticity of the provided documents, and carrying out the verification on our behalf. Such a third-party service provider will be ensured to comply with our Privacy Policy and the applicable data protection laws to guarantee the security and confidentiality of users’ personal information.
As soon as we receive the requested documentation, the evaluation process is conducted either programmatically with the assistance of AI software via our third-party verification partners and/or manually depending on the case and in accordance with the AML Procedures that were enforced.
3.2 Data Storage
The provided by the user documentation will be securely stored according to the provisions of the applicable data protection laws and for so long as required by law. Such documents are never disclosed, excluding competent authorities and investigative bodies provisioned in our Privacy Policy, after their relevant official request.
3.3 Positive Result
If the documents and the verification procedure are found to be valid and in line with our TOS and applicable laws, the verification is finalized successfully and the transaction is processed automatically.
3.4 Negative Result
In the event that the user fails to successfully complete the KYC verification and/or whose details and account(s) appear to be blacklisted and/or on sanction lists, and/or in violation of our Customer Acceptance Policy or TOS, and/or fails to provide the requested documentation, and/or what provided can not be deemed as authentic, The Change reserves the right to refuse - stop providing its services to the client, the transaction will not be processed, and the deposited amount will be refunded, however, the client is liable to compensatory charges for any damages The Change may suffer in this regard.
In cases where: we suspect that a user has failed to perform a KYC on our relevant request in the past, or the transaction is suspected of being related to illegal activities, we reserve the right to freeze the transaction and/or transfer the frozen funds to a cold storage wallet for any period of time necessary to complete the investigation and our AML/KYC procedure, and/or report the case to authorities for further investigation.
4. Limitation of Liabilities
The Change takes all necessary actions and measures, uses the best available practices, and the most efficient course of action in order to prevent any fraudulent - illegal activity from occurring. Subsequently, we do not engage in any way and refuse to develop any business relationship, and/or provide our services to any legal entity suspected of money laundering, terrorism financing, corruption, fraud, illegal transfer of assets, drugs, humans, organs, and/or any other illegal trafficking, and/or any other illegal activity. In no event shall The Change, the owner, our directors, officers, members, or any kind of employees or agents, be liable or responsible, if our services are being used by any client, for any illegal activity and/or in violation of any applicable law, regardless of if the associated user has passed a KYC verification procedure, and exempts liability, for any deficiency or error that may arise as a result of human or system error, in identifying any suspicious transaction and/or user activity, and in proactively denying our services to any user suspected of, or associated with, any illegal activity.
If you have any questions related to our AML Policy, please contact us at [email protected].