AML/CTF and KYC Policy

Policy
anti-money laundering
AML
(anti-money laundering policy)

Effective date: 11/01/2021.
Updated 05/27/2022.
This AML Policy (hereinafter referred to as the Policy) governs bullschange.com’s anti-money laundering activities and its involvement in the fight against money laundering and terrorist financing.

Terms and definitions

bullschange.com is a trademark of a system that provides Users with the opportunity to exchange digital and electronic currencies.
Service – a system for providing Internet services for the exchange, sale and purchase of digital and/or electronic currencies.
User – this is any individual using the services of the bullschange.com service.
Digital currency – Bitcoin, Litecoin, Ethereum and any other currencies based on the blockchain.
Electronic currency – funds held in the accounts of users of electronic payment systems (Qiwi, Yandex Money, etc.).
Service services – providing assistance in conducting peer-to-peer transactions between individuals for the purchase and sale and exchange of digital currencies, as well as other services, information about which is posted on the Service showcase.
Card verification – this is a verification of the ownership of the card (or account) to its owner. The conditions for checking affiliation are established by the Service and are carried out once for each new account (card) of the User.
Money laundering – giving legal form to the possession, use or disposal of funds or other property obtained as a result of the commission of a crime. bullschange.com strictly follows laws that prohibit us or any of our employees from knowingly engaging in or attempting to engage in any activities related in any way to money laundering. Our anti-money laundering policy is aimed at increasing the security of clients and the services provided by the Service.
Financing of terrorism – intentionally providing or collecting, by any means, directly or indirectly, funds with the intention of using these funds or on the condition that they will be used to commit terrorist acts.

2. Activities taken to comply with the AML Policy

The administration of the bullschange.com service, understanding the public danger of crimes related to money laundering and the financing of terrorist activities, has developed a set of organizational and legal measures in order to comply with the provisions of national legislation, as well as the requirements of the intergovernmental organization FATF.
European AML regulation is based on a number of legislative directives. Namely, the EU issued the Sixth Anti-Money Laundering Directive (6AMLD), which came into force on December 02, 2018.
Other legislative acts aimed at combating money laundering and the financing of terrorism are the following acts:

• 5th Anti-Money Laundering Directive ((EU) 2018/843);
• Proceeds of Crime Act 2002;
• Terrorism Acts 2000 and 2001;
• Anti-Terrorism Act 2008;
• Treasury Sanctions Notices;

1. Application of the KYC (know your customer) policy. Mandatory identification of Users who are allowed to make transactions on our Service. To verify the User, the Administration has the right to require the following data:
   take a photo (“selfie”) with a citizen’s identification document: a scanned copy of the front and back of an official photo ID, i.e. a valid passport, driver’s license or other national ID;
   Proof of Residence: An official document issued within the last 3 months clearly indicating the client’s name and address as provided when registering on bullschange.com. This could be a utility bill (water, electricity or landline) or a bank statement. The copy must include: full name, full residential address, date of issue (within the last 3 months), name of the issuing authority with official logo or seal;
   provide a copy of the front and back sides of the bank card and/or a photograph of your bank card taken against the background of the main page of the Service (showcase with services). To ensure privacy and security, only the last 4 digits of your credit card should be visible. It is allowed to hide 3 digits on the back of the card (CVV code).
   The administration of the bullschange.com service will take steps to confirm the authenticity of documents and information provided by Users. Identification information will also be verified using secondary sources, and the Service Administration reserves the right to continue to investigate cases to obtain full confidence in the authenticity of the documentation provided.
   The administration of the bullschange.com service reserves the right to monitor the User’s data on an ongoing basis, especially in cases where his identification information has been changed or his activity seemed suspicious (unusual for a particular User). In addition, the Administration reserves the right to request current documents from Users, even if they have been authenticated in the past.
2. Carrying out constant monitoring of transactions passing through the Service. We constantly monitor all applications created on bullschange.com. The service administration notifies Users of the prohibition on carrying out exchange transactions from third parties using their account.
3. Appointment of a responsible person (MLRO – Money Laundering Reporting Officer) exercising control and supervisory powers to implement the provisions of this Policy.
4. Application of a risk-based approach (RBA – Risk-Based Approach). We implement different levels of verification, depending on the volume and number of transactions performed by the User.
5. Improving the professional skills and knowledge of bullschange.com team members in terms of compliance with the requirements of the Policy.
6. Interaction with government agencies in cases established by law. If we receive a formal request from law enforcement or judicial authorities, we will be required to provide them with the requested information. The Service Administration also has the right to provide data requested by official representatives of payment systems.
7. Improving the security of bullschange.com service software. We care about the reliability and security of your transactions. In this regard, we are constantly improving our IT department, the main task of which is to protect the site from unauthorized access by intruders.
8. The administration of the bullschange.com service, in cases prescribed by law, may require a regulatory requirement to verify the source of fiat money and/or cryptocurrency to ensure that the sources of the Funds that the Client uses for exchange are legal. Documentation confirming the source of the Funds may be a bank statement for fiat money or a video showing details of a wallet transaction for cryptocurrencies.
9. In accordance with this Policy, the Service Administration will:
   — monitor all transactions. The Administration reserves the right to ensure that reports of suspicious transactions are reported to the appropriate law enforcement authorities through the Responsible Official;
   — request from the User any additional information and documents in the event of suspicious transactions, also at the request of the regulator (The role of the regulator may be an exchange, government agency or other organization that has the appropriate legal grounds.);
   — suspend or terminate a User’s account if there is reasonable suspicion that such User is involved in illegal activity.
10. However, the above list is not exhaustive and the Responsible Official will monitor Users’ transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or treated as in good faith.
11. Country of stay. This Policy defines our risk criteria in relation to AML/CTF. To reduce this risk, the administration of the bullschange.com service does not accept clients who reside in the following countries with an increased risk criterion:

Sources used for categorization:

• Transparency International;
• Know Your Country;
• FATF list of high-risk jurisdictions;
• List of EU high-risk jurisdictions;
• Countries where digital assets are prohibited or have trade restrictions;
• Countries that do not prohibit digital assets;
• Countries subject to the UN Security Council sanctions regime.
• All clients residing in the countries listed below are prohibited from service on the BullsChange.com service and cannot be accepted as Users.
• Any customers from these countries will be denied service and any funds will be returned to the source.
• Full list of prohibited jurisdictions:

USA
Afghanistan
Albania
Angola
Algeria
Bangladesh
Barbados
Bolivia
Botswana
Burma (Myanmar)
Burundi
Cambodia
Central African Republic
Chad
Congo
Conakry
Ivory Coast
Crimea (Ukraine)
Cuba
Democratic People’s Republic of Korea (DPRK)
Ecuador
Egypt
Equatorial Guinea
Eritrea
Ghana
Guinea-Bissau
Haiti
Guyana
Iran
Iraq
Lao People’s Democratic Republic
Lebanon
Libya
Mali
Morocco
Myanmar
Nepal
Nicaragua
North Macedonia
Pakistan
Panama
Qatar
Saudi Arabia
Somalia
South Sudan
Sudan
Syria
Tunisia
Uganda
Vanuatu
Venezuela
Yemen
Zimbabwe
Jamaica

The administration of the bullschange.com service also does not accept clients from disputed territories, since they do not provide generally accepted official documents, including:
Donetsk People’s Republic (DPR) / Lugansk People’s Republic (LPR)
Pridnestrovian Moldavian Republic
Nagorno-Karabakh Republic
Republic of Abkhazia
Republic of Somaliland
Republic of South Ossetia
Turkish Republic of Northern Cyprus
Republic of China (Taiwan)
Passports issued by the Russian Federation in Crimea and passports issued to residents of the Donetsk and Lugansk regions of Ukraine are not subject to verification
Republic of Kosovo
Sahrawi Arab Democratic Republic
Republic of Artsakh

Funds transferred from the following platforms will be blocked.

Red risk platforms:

Black Sprut

Wasabi Wallet

Bitzlato

Hydra

Garantex

Tornado Cash

OMG!OMG!

MEGA DARKNET MARKET

FreeBitcoin
Casino
Gambling
1xBet

We would like to note that any transactions with a total risk above 40% will be blocked!

KYC Policy
(Know Your Transaction)

Effective date: 11/01/2021.
Updated 08/23/2022.
The KYC (Know Your Transaction) policy is aimed at identifying the transaction client in the event of a precedent where the Service has reasonable suspicions that the Client is using bullschange.com inappropriately.

Such a precedent may arise if the Service suspects the Client of illegal actions that may be qualified as laundering or an attempt to launder digital assets obtained illegally or the funds are of outright criminal origin. For these purposes, the Service has the right to use any legal information, third-party tools for analyzing the origin of digital assets, as well as its own developments of a screening system.

When conducting an AML check, the exchanger also focuses on a detailed analysis of a specific transaction. In the event that a detailed analysis reveals a risk of more than one of the following:

– Darkmarket 0.1%
– Dark Service 0.1%
– Scam 0.1%
– Stolen 0.1%
– Mixer 0.1%
– Exchange Fraudulent 0.1%
– Illegal Service 0.1%
– Ransom 0.1%
– Terrorism Financing 0.1%
– Gambling 0.1%
– Enforcement Action 0.1%
– Sanctions 0.1%

The exchange service uses the following analyzers: Rapira.net, @BitOK_AML_bot

If the Client has not checked his assets for the presence of tags, or has not asked for verification from the operator, then the Client accepts the risks of blocking the funds.

The administration of the exchange office has the right to request identity verification (KYC) to return funds.

Passing KYC

To pass KYC, the client must provide a video with a passport in hand against the background of the application (with readable data: passport series and number, full name), without interruption in the video, demonstrate the wallet/account from which the transaction was sent (with readable data: date and time, amount, transaction hash and recipient address). The period for information verification by the security service of the exchange office can be up to 24 hours from the moment the video is provided. In exceptional cases (if additional requests from payment systems or exchanges are necessary), the period may be extended to 48 hours.

In this case, the bullschange.com Service reserves the full right to:

1. Require the Client to provide additional information disclosing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
2. Block the account and any transactions related to the Client, transfer to the financial control and/or law enforcement authorities at the place of registration of the Service and, if necessary, at the Client’s registration address all information and documents available on the incident;
3. Require from the Client documents confirming identity, physical existence, registration address, solvency;
4. Return digital assets only to the details from which the transfer was made or switch to other details after a full check by the Service’s security service, if it was possible to verify the legal origin of the Client’s funds;
5. Refuse the Client to withdraw funds to a third party account without giving reasons;
6. Hold the Client’s funds until the incident is fully investigated;
7. The service reserves the right to monitor the entire chain of transactions in order to identify suspicious transactions;
8. The Service reserves the right to refuse to provide the service to the Client if the Service has reasonable suspicions about the legality of the origin of digital assets and to hold funds in special accounts of the Service;
9. The Service reserves the right to refuse to provide a service to the Client if the Service has reasonable suspicions about the legality of the origin of digital assets and to hold funds in special accounts of the Service if it is impossible to track the entire chain of movement of digital assets from the moment of their appearance.

Conditions for returning funds stopped for verification based on the results of AML analysis of the transaction:

Refunds are made after a full check by the Service’s security service, which may include detailed verification of the sender. Refunds are made minus a commission of up to 5%, but not more than $100 of the transaction amount to cover labor costs for processing the application and organizing the refund. For clients who have successfully completed KYC, or in the absence of evidence of a connection to money laundering, the commission is limited to the network commission only.
The return, subject to approval by the Service, will be processed by the Service from 7 (seven) to thirty (30) calendar days, starting from the date on which the User was notified of the Service’s decision regarding his return request.
When applying for a refund, after passing the check (verification), the user is required to confirm the details for receiving the refund.