Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy

Cryptocurrency exchange service EasySwap

Effective Date: January 5, 2026

Basis: International FATF standards and national legislation of the countries of presence

1. General Provisions and Objectives

EasySwap Platform (hereinafter referred to as the "Service") adheres to financial compliance standards. This Policy governs the company"s activities and is aimed at achieving the following objectives:

* Preventing the use of the service for illegal activities;

* Guarantee of compliance of work with regulatory requirements;

* Maintaining business reputation and maintaining customer trust;

* Compliance with FATF recommendations and the laws of the jurisdictions where the Service operates.

2. Customer Identification and Verification (KYC)

Verification levels and limits

To expand the platform"s functionality and increase asset withdrawal limits, all users are required to undergo a KYC (Know Your Customer) verification process. The EasySwap platform verifies data through integration with specialized third-party providers. The verification system provides two access levels, which determine available financial limits:

Basic level of identification

This stage involves a standard verification procedure and is required for most banking lines and low-risk transactions. The following information is required to complete this level:

valid email address;
user"s identity document;
confirmation of actual residential address.

Advanced Identification Level

Enhanced verification is initiated when a user is assigned a high-risk status under the AML policy or when conducting high-risk transactions. Requested data may include:

email contacts;
identity verification;
documentary proof of place of residence;
information on the origin of funds (Source of Funds).

The decision to upgrade to an advanced level, as well as the request for additional documents, remains at the discretion of the platform"s security service and is made on an individual basis based on a risk assessment of the specific situation.

List of documents

To confirm identity, the client can provide one of the following documents:

* Internal passport;

* International passport;

* Driver"s license.

To confirm your residential address, we accept (optional):

* Certified lease agreement or bank statement;

* Receipts for utilities or electricity;

* Tax return;

* Other official documents indicating the address for the last 3 months.

Documentation requirements

* Presence of duplication of data in Latin transliteration;

* Documents must be current, reliable and issued by independent bodies;

* It is mandatory to provide a customer selfie with the “EasySwap” sign and the current date.

Verification of the legitimacy of the origin of assets (Source of Funds)

During the enhanced identification process, the Client is required to document the legal origin of the funds used. The following types of documentation may be requested for this purpose (the list is not exhaustive):

certificates of earnings or other evidence of regular labor income;
current employment contracts or civil law contracts;
reporting documents of the tax authority (declarations);
bank account statements showing the receipt of funds;
confirmation of receipt of investment income or dividend payments;
agreements on alienation of property (real estate, transport, etc.);
certificates of inheritance;
gift agreements;
statements of income from commercial activities;
other documents certifying the legal nature of financial receipts.

EasySwap Administration reserves the discretionary right to request additional information or documentation based on the specifics of the transaction and the results of the risk assessment.

Additional terms and conditions

* EasySwap reserves the right to initiate re-verification if suspicious activity is detected.

* Providing services to users from jurisdictions blacklisted by FATF, OFAC, EU, UN, as well as: Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma) is prohibited.

* Verification times: standard procedure takes 1–24 hours, extended procedure (EDD) – from 24 to 72 hours.

3. Transaction monitoring (KYT)

Tools

EasySwap uses a combination of automated and manual transaction analysis methods, using specialized providers (including AMLBot and similar ones).

Risk assessment criteria

The analysis is carried out in the following areas:

Sanctions lists: checking addresses for affiliation with “black” clusters (darknet, fraud, stolen funds).
Anonymizers: detecting the use of mixers, tumblers and related protocols.
Suspicious patterns:

* Fractional transfers (smurfing);

* Transaction volumes that are abnormal for the user"s history;

* Transactions initiated from high-risk jurisdictions.

Risk scoring: assignment of status Low / Medium / High .

Risk assessment scale

The assessment depends on the provider"s methodology and is subjective:

* Low: score ≤ 62% based on provider model.

* Medium: score 62% - 70%.

* High: score 70% - 75%.

Risk Score Label Categories for Cryptocurrency Addresses

Transactions marked "High Risk" may be blocked automatically and transferred to an AML officer for manual review. We recommend performing manual checks before sending a transaction to an exchange service to ensure the address is risk-free. Our checks are performed using AML bot processing. To pre-check your address, you can visit our service page or use the following resource: https://www.bestchange.com/report/

4. Categorization of clients by risk level

Depending on the client profile, different control measures and re-checking frequencies are applied:

* Low risk. Standard CDD verification is applied. Re-verification is carried out as needed.

* Medium risk. Enhanced monitoring is introduced. Re-checks are conducted every two years.

* High risk. Enhanced Due Diligence (EDD) applies: source of funds is requested, in-depth transaction analysis is conducted, and annual KYC updates are required.

Automatic classification as high risk

The following are automatically classified as high risk:

* PEP (politically exposed persons) and their close relatives;

* Residents of countries from the FATF High-Risk Jurisdictions list;

* Clients with an annual turnover of over $100,000.

5. Service Obligations and Transaction Requirements

EasySwap Guarantees

Implementation and compliance with KYC/KYT procedures and risk assessment.
Monitoring transactions and blocking them when AML/CTF threats are detected.
Transfer of data to authorized bodies in cases provided by law.
Storing customer data and transaction history for at least 5 years.
Regular training of staff on compliance standards.
Ensuring the legitimacy of assets sent to clients.

Requirements for outgoing transfers

* Use of unique (one-time) crypto addresses.

* Sending funds only to addresses with a low risk level according to AML analysts.

* Priority is given to addresses of licensed platforms.

All payments are made in accordance with the requirements of FATF, OFAC and other international regulators.

6. Actions upon detection of suspicious activity

If signs of illegal activity are detected, the Platform will act as follows:

The operation is suspended immediately.
The account is blocked until the internal investigation is completed.
An internal report (SAR/STR) is generated.
If necessary, notifications are sent to the competent authorities (Rosfinmonitoring, FinCEN, EU FIU, etc.).

Refunds and fees

* The fee for refunding funds in AML cases is up to 5% of the amount, but does not exceed $100.

* Refunds are not possible if assets are found to be related to illegal activity or are subject to seizure at the request of authorities.

* For bona fide clients who have completed KYC/SoF procedures, the commission is limited to network fees only.

A client"s refusal to provide information or failure to undergo verification shall serve as grounds for termination of service.

7. Working with partners and data protection

Counterparties

The platform does not partner with services from jurisdictions with weak AML regulations. Due diligence is conducted on all partners (exchanges, payment gateways, API providers). Counterparties are required to be licensed and comply with international standards.

Data security

All personal and transactional data:

* Encrypted in accordance with industry security standards.

* Stored on secure servers in GDPR and MiCA compliant jurisdictions.

*Available only to authorized personnel.

* Retained for at least 5 years after termination of the relationship with the client (unless the law requires a different period).

This privacy policy applies to the EasySwap website and mobile app.

8. Internal control and final provisions

Monitoring and training

An AML officer has been appointed responsible for the implementation of the Policy.
All employees undergo annual training on AML/CTF standards.
Quarterly internal audits are conducted, with the involvement of independent experts if necessary.

Legal terms

* This Policy is an integral part of the EasySwap User Agreement.

* The service reserves the right to make changes unilaterally by notifying users through the website.

* Use of the Platform services constitutes automatic agreement with the terms of this Policy.

Contacts

Reports of suspicious activity and inquiries to the responsible AML officer should be sent to: support@easyswap.me