1. Introduction
The policy of countering the legalization of proceeds obtained through criminal means, and "Know Your Customer" (hereinafter referred to as "AML/KYC Policy"), is designed to prevent and mitigate potential risks of Coincraddle.com being involved in any illegal activities.
2. Objective of Internal Regulations
Coincraddle.com adheres to practices and measures in the field of combating the legalization (money laundering) of proceeds obtained through criminal means and the financing of terrorism (AML). The purpose of these measures is to demonstrate that Coincraddle.com takes seriously any attempts to use its service for illegal purposes.
3. Warning
Coincraddle.com service cautions users against attempting to use the Coincraddle.com service for the legalization of funds obtained through criminal means, financing terrorism, any form of fraud, as well as for the purchase of prohibited goods and services. Coincraddle.com service, its administration, employees, and domain owners are not responsible for the unauthorized use of the service by third parties, the actions of malicious actors, and any potential damage associated with the use of the Coincraddle.com service.
4. Requirements
To prevent illegal transactions, Coincraddle.com service establishes specific requirements for all Requests created by the User:
4.1. The sender and recipient of the Payment in the Request must be the same person. The use of the Service for transfers to third parties is strictly prohibited.
4.2. All contact details entered by the User in the Request, as well as other personal data transmitted by the User to the Service, must be current and completely accurate.
4.3. It is strictly prohibited to create Requests by the User using anonymous proxy servers, VPN, Tor, or any other anonymous Internet connections.
5. Verification Procedures
One of the international standards for preventing illegal activities is proper customer verification (hereinafter referred to as "Verification"). To this end, Coincraddle.com implements its own verification procedures in strict compliance with anti-money laundering standards and the "Know Your Customer" procedure.
5.1. Coincraddle.com service may require the User to provide reliable, independent original documents, data, or information to undergo verification and confirm the sources of funds. The required documents may include:
- A photo with a passport, unfolded, clearly showing the photo and full name;
- Scan or photo of the passport (first, second pages, and the page with the registration in high quality);
- Confirmation of the sources of funds (photos, screenshots, statements);
- A video of the person sending the funds with the passport in hand in an unfolded state (clearly showing the photo, full name), stating that they created a Request ID (request number) on the Coincraddle.com exchange, the funds sent are personal, and they take full legal responsibility for the cryptocurrency, also mentioning the source of the funds on the video;
- Record a video taken from the platform where the funds were sent, showing the hash, sender and recipient addresses, amount with the ticker, and the date of the transaction. The duration of the video should be at least 10 seconds.
5.2. In case of blockages due to high risk or official investigation, funds will be held until verification is completed or the investigation is concluded. For these purposes, Coincraddle.com service reserves the right to collect User identification information for AML/KYC Policy compliance.
5.3. Coincraddle.com service will take steps to verify the authenticity of documents and information provided by Users. All legal methods for double-checking identification information will be used, and Coincraddle.com service reserves the right to investigate cases of specific Users whose identities have been identified as dangerous or suspicious.
5.4. Coincraddle.com service reserves the right to verify the identity of the User on a continuous basis, especially when their identification information has changed or their activity seems suspicious (unusual for a specific User). Additionally, Coincraddle.com service reserves the right to request current documents from Users, even if they have passed authenticity verification in the past.
5.5. User identification information will be collected, stored, shared, and protected strictly in accordance with the Privacy Policy of Coincraddle.com service and relevant regulations.
5.6. After confirming the user's identity, Coincraddle.com service may refuse to provide services to the User in situations where Coincraddle.com service is used for illegal activities.
5.7. Coincraddle.com service has regulatory requirements for verifying the source of financial funds or cryptocurrencies to ensure that the sources of funds that Users use for trading are legitimate.
6. Responsible Officer
The person responsible for compliance with AML standards is an individual duly authorized by Coincraddle.com service, whose duty is to ensure the effective implementation and compliance with the AML/KYC policy.
6.1. The responsibility of such an officer includes monitoring all aspects of Coincraddle.com's activities in countering the legalization of proceeds obtained through criminal means, including money laundering and terrorism financing, including but not limited to the following methods:
- collecting user identification information;
- creating and updating internal policies and procedures for completing, reviewing, submitting, and storing all reports and records required by applicable laws and regulations;
- monitoring transactions and investigating any significant deviations from normal activity;
- implementing a records management system for the proper storage and retrieval of documents, files, forms, and logs;
- regularly updating risk assessment;
- providing law enforcement with information required by applicable laws and regulations.
6.2. The officer responsible for compliance with AML standards has the right to interact with law enforcement agencies involved in preventing money laundering, terrorism financing, and other illegal activities.
7. System Functions
Coincraddle.com service performs various tasks related to compliance, including data collection, filtering, record-keeping, investigation management, and reporting. System functions include:
- daily checks of users against recognized "blacklists" (e.g., OFAC), aggregating transfers across multiple data points, placing users on watchlists and denying services, opening cases for investigation where necessary, sending internal messages, and completing mandatory reports if applicable;
- case and document management.
8. Behavioral Analysis
Coincraddle.com service checks users not only by verifying their identity but, more importantly, by analyzing their behavior in transactions. Therefore, Coincraddle.com service relies on data analysis as a tool for risk assessment and suspicion detection.
9. Risk Assessments
In accordance with international requirements, Coincraddle.com applies the practice of risk assessment to combat money laundering and terrorism financing. By applying the practice of risk assessment to combat money laundering, Coincraddle.com ensures proportionality of measures to prevent or reduce money laundering and terrorism financing risks.
10. Customer Checks
In case the administration of Coincraddle.com service has reasonable suspicions that a user is attempting to use the service for money laundering or any other illegal operations, the administration has the right to:
- suspend the execution of the user's exchange operation;
- request identity documents from the user;
- request any additional information and documents from the user in case of suspicious transactions;
- ensure that messages about suspicious transactions are conveyed to the appropriate law enforcement authorities through the officer responsible for AML compliance.
11. Confidentiality
Coincraddle.com service guarantees client confidentiality in accordance with the service's privacy policy.
11.1. Coincraddle.com service and its employees commit to maintaining confidentiality regarding any facts identified in connection with any suspicious transaction. This obligation also extends to service users and third parties to whom information about the transaction has been disclosed.
11.2. The obligation to ensure confidentiality, imposed on Coincraddle.com service employees, remains in effect after the termination of their employment or any other contractual relationship with Coincraddle.com service, as well as in the event of their transfer to another position. Disclosure of such information to state, law enforcement authorities, and other entities in cases defined by law does not constitute a breach of confidentiality obligations.
11.3. The obligation to ensure confidentiality, provided that the use of the disclosed information is limited to preventing the legalization of proceeds from crime and terrorism financing, cannot apply to the disclosure of information between financial institutions forming a consolidated group that collaborates with Coincraddle.com service.
12. Conclusion
In light of the above, Coincraddle.com service assumes no legal responsibility for its use in the legalization of funds obtained through criminal means, terrorism financing, or the purchase of prohibited goods and services. However, it undertakes all possible and available actions to prevent attempts to use Coincraddle.com service for the legalization of funds obtained through criminal means, terrorism financing, or the purchase of prohibited goods and services. By making an exchange, the user, in accordance with the rules in effect on Coincraddle.com, agrees to all the terms of these policies and undertakes to comply with them.