AML/KYC Policy
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1. Introduction
HiExchange has implemented an Anti-Money Laundering and Know Your Customer Policy (referred to as "AML/KYC Policy") to prevent and mitigate the risks of being involved in illegal activities.
2. Purpose of Internal Regulation
HiExchange is committed to implementing practices and measures to combat money laundering and terrorism financing. These measures demonstrate HiExchange's commitment to preventing any misuse of its services for illegal purposes.
3. Caution
Users are strictly warned against attempting to use HiExchange for money laundering, terrorist financing, fraud, or the purchase of prohibited goods and services. HiExchange, including its administration, employees, and domain owners, are not responsible for any misuse of its services by third parties or any damages associated with such misuse.
4. Requirements
To prevent illegal transactions, HiExchange sets certain requirements for all user applications:
4.1. The sender and recipient of payments must be the same person. Transfers in favor of third parties are strictly prohibited.
4.2. All contact information and personal data provided by users must be up-to-date and accurate.
4.3. Users are prohibited from creating applications using anonymous proxy servers, VPN, Tor, or any other anonymous internet connections.
5. Verification Procedures
HiExchange follows international standards for customer due diligence, implementing its own verification procedures in strict adherence to anti-money laundering and Know Your Customer regulations.
5.1. Verification Requirements In order to pass the verification process and confirm the origin of funds, HiExchange may require Users to provide reliable and independent source documents or information. This may include:
A clear and expanded photo of the passport with the user's photo and full name visible;
A scan or photo of the passport's first, second, and registration pages in good quality;
Confirmation of the sources of funds with photos, screenshots, or extracts;
A video in which the person who sent the funds holds an expanded passport (with the photo and full name visible), states their HiExchange application ID (application number), confirms that the funds sent are their own and that they bear full legal responsibility for the cryptocurrency, and mentions the source of the funds on the video;
A video recording taken from the platform where the funds were sent from, showing the hash, sender and recipient addresses, amount with the ticker, and date of the transaction. The video must be at least 10 seconds long.
5.2. Verification Delays In case of high risk or official investigation, funds may be held until the verification process or investigation is completed. HiExchange reserves the right to collect the User's identification information for compliance with the AML/KYC Policy.
5.3. Authenticity Verification HiExchange will take steps to verify the authenticity of documents and information provided by Users, using legal methods for double verification of identification information. HiExchange also reserves the right to investigate cases where a User's identity is considered dangerous or suspicious.
5.4. Ongoing Identity Checks HiExchange may check the User's identity on an ongoing basis, especially when there are changes to the identification information or suspicious activity is detected. HiExchange may also request up-to-date documents from Users, even if they have been authenticated in the past.
5.5. Privacy and Data Protection User identification information will be collected, stored, shared, and protected in strict accordance with HiExchange's Privacy Policy and related rules.
5.6. Refusal of Services After confirming the User's identity, HiExchange may refuse to provide services if the User's account is found to be used for illegal activities.
5.7. Payment Card Verification Users intending to use payment cards for services must undergo card verification as per the instructions available on the HiExchange website.
5.8. Source of Funds Verification HiExchange has regulatory requirements to verify the legality of the source of funds or cryptocurrency used by Users for trading.
6. Responsible Official
The HiExchange Service appoints a person responsible for AML compliance who is authorized to ensure effective implementation and enforcement of the AML/KYC policy. This person is responsible for various tasks including collection of user identification information, creating and updating internal policies and procedures, monitoring transactions, implementing a records management system, updating risk assessment, and providing information to law enforcement agencies as required by applicable laws and regulations.
7. System Functions
The HiExchange Service performs various compliance tasks such as data collection, filtering, record keeping, investigation management, and reporting. System features include checking users against recognized blacklists, aggregating transfers, placing users on watchlists and denial of service lists, opening cases for investigation, sending internal messages, and filling mandatory reporting if applicable.
8. Behavior Analysis
The HiExchange Service verifies users not only by verifying their identity, but also by analyzing their behavior in transactions. Data analysis is used as a risk assessment and suspicion detection tool.
9. Risk Assessments
The HiExchange Service applies the practice of risk assessment to combat money laundering and terrorist financing, in accordance with international requirements. This ensures that measures to prevent or reduce money laundering and terrorist financing are proportionate to the identified risks.
10. Perform Customer Checks
In order to combat money laundering and illegal activities, HiExchange service has the authority to suspend user's exchange operation, request identification documents, and seek additional information for suspicious transactions if the administration has reasonable suspicions. They also have the responsibility to report any suspicious transactions to law enforcement authorities through the designated AML Compliance Officer.
11. Privacy
HiExchange service places a high value on client confidentiality and ensures that employees maintain strict confidentiality regarding any information related to questionable transactions. This obligation extends even after termination of employment or contractual relationship. However, disclosure of information to government, law enforcement agencies, and other entities in accordance with the law is not considered a violation of confidentiality obligations.
11.1. The HiExchange service and its employees undertake to maintain confidentiality regarding any facts revealed in connection with any questionable transaction. This obligation also applies to users of the Service and to third parties to whom information on the transaction was transferred.
11.2. The confidentiality obligation imposed on the employees of the HiExchange Service remains in force after the termination of their work or any other contractual relationship with the HiExchange Service, as well as when such employees are transferred to another workplace. Disclosure of such information to government, law enforcement agencies and other entities in cases specified by law is not a violation of confidentiality obligations.
11.3. The obligation to maintain confidentiality, provided that the use of the information disclosed is limited to preventing the legitimization of proceeds of crime and terrorist financing, cannot apply to the disclosure of information between financial institutions that form a consolidated group that cooperates with the HiExchange Service.
12. Conclusion
HiExchange service acknowledges that it does not hold legal responsibility for any misuse of its services for money laundering, terrorist financing, or purchasing prohibited goods/services. Nevertheless, HiExchange service is committed to taking all possible and available actions to prevent any attempts to use its platform for illegal purposes. By making an exchange, users agree to comply with the AML/KYC policies and exchange rules in force on HiExchange.