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Anti-Money Laundering and Customer Verification Policy (AML/KYC)

Anti-money laundering policy, transaction monitoring, and user verification

1. General Provisions

This Policy establishes the procedure for AML/KYC checks of transactions and users of the LeoExchanger service, as well as the risk assessment criteria used by the service to decide on processing, suspension, additional review, or refund of funds.

LeoExchanger follows a risk-based approach to cryptocurrency operations. Each transaction may be checked both automatically and additionally manually, using AML analytics tools, the service's internal rules, and the rules and algorithms of connected merchants, payment providers, and compliance partners.

The purpose of such screening is to identify transactions potentially linked to fraud, sanctions restrictions, anonymization services, stolen assets, terrorist financing, or other sources of elevated AML risk.

2. AML Analytics Tools

To analyze cryptocurrency transactions, LeoExchanger may use Crystal Intelligence and/or other recognized AML analytics solutions, as well as the internal algorithms of merchants, payment providers, and compliance partners.

A decision regarding a specific transaction is made taking into account a combination of factors — the results of AML analysis, risk structure, categories of risk sources, and internal merchant rules.

3. Risk Assessment, Risk Score, and Critical Categories

LeoExchanger uses an aggregate Risk Score as one of the criteria for assessing a transaction.

The Risk Score serves as a guideline in decision-making but does not by itself always result in automatic blocking of a transaction, in the absence of critical or elevated risk flags.

When assessing a transaction, the service considers not only the overall risk level but, above all, the presence of the Very High Risk and High Risk categories identified by analytics systems.

3.1. Very High Risk

The Very High Risk category includes, among others: Enforcement Action; Fraudulent Exchange; Terrorist Financing; Child Abuse / Human Trafficking.

If a risk share above 0% is identified under any Very High Risk category, the transaction is deemed critical and is automatically suspended for further AML/KYC/Compliance review.

3.2. High Risk

The High Risk category includes, among others: Black Market Services; Illegal / Crime-Related Activities; Scam / Fraud; Mixer / Tumbler / Privacy Tools; Malware / Ransom; Stolen Funds / Hack / Exploit; Drainer Wallets; Blackmail / Sextortion; Ponzi / HYIP.

If a risk share above 1% is identified under any High Risk category, the transaction is automatically suspended for further review.

If no individual High Risk category exceeds 1%, but their combined share exceeds 5%, the transaction may likewise be suspended for in-depth AML analysis, verification of the source of funds, and a request for supporting documents.

4. Grounds for Suspending a Transaction

A transaction is suspended if:

  • the overall Risk Score exceeds the threshold set by the service;
  • a Very High Risk category is identified within the scope defined by this Policy;
  • a High Risk category is identified within the scope defined by this Policy.

While a transaction is suspended, the exchange is not completed until the results of the review and/or a decision from the merchant, payment provider, or AML provider are received.

5. The Service's Right to Request Information and the User's Obligation to Provide It

Within the AML/KYC/Compliance procedure, LeoExchanger is entitled to request information and documents from the user, and the user is obliged to provide them within the timeframe set by the service.

The service may request, among other things:

  1. identification data and an identity document;
  2. video verification or a liveness check;
  3. confirmation of the source of funds — explanations, transaction history, screenshots, statements, TXIDs, wallet addresses, and other materials sufficient to assess the origin of the funds;
  4. additional materials via email or another official communication channel, if the information provided is insufficient.

To verify identity, the service uses KYCAID and/or other verification providers, which covers document verification, a liveness check, and verification of the source of funds.

6. Timeframes for Providing Information and Conducting Additional Review

The user is given up to 10 business days to submit the requested information, documents, and explanations.

If the requested information is not provided within the set timeframe, the transaction may be escalated for further review for a period of up to 30 business days.

If further escalation to the merchant, an AML provider, or, where applicable, competent authorities is required, the review period may be extended.

7. Refunds, In-Depth Investigation, and Escalation

LeoExchanger does not hold funds indefinitely. A further decision on a transaction is made within the AML/KYC/Compliance procedure based on the results of the review, the conclusions of the merchant, payment provider, or AML provider, and the technical feasibility of processing a refund.

A refund is not automatic and is not made immediately upon the user's request.

If a refund is approved, it is made exclusively to the same wallet from which the transaction was carried out.

If a transaction was suspended due to a High Risk category or any link to Very High Risk, completing the KYC/AML procedure is mandatory in order to consider a refund.

If the user refuses to undergo the requested review or does not provide the required materials, the case may be referred for in-depth investigation and escalated to the merchant, payment provider, compliance department, or AML provider.

In cases required by law, by a compliance partner's requirements, or where there are indications of unlawful activity, case materials may be forwarded to competent authorities.

8. Merchant Fees and Additional Costs Upon Refund

When funds are refunded, the following may be deducted:

  • network fees;
  • fees charged by the merchant, payment provider, or another technical provider;
  • other actual costs directly related to processing the refund.

In certain cases, additional costs may arise depending on the specific situation, the refund structure, or the requirements of an external provider.

Such additional costs may amount to up to 5% of the refund amount, but no more than 100 USD.

9. Sanctioned Jurisdictions, Prohibited Platforms, and Sources of Elevated Risk

LeoExchanger does not work with high-risk or sanctioned platforms, or with platforms from jurisdictions subject to sanctions or other international restrictions. Applicable sanctions restrictions are determined, among other things, by reference to the OFAC sanctions lists and other applicable compliance sources, taking into account sanctions-related links and relevant risk information sources.

LeoExchanger does not accept funds linked to high-risk platforms, sanctioned jurisdictions, anonymization services, fraudulent schemes, stolen assets, darknet marketplaces, or other sources of unacceptable AML risk.

Such platforms and sources include, among others:

Netex24.net; Bitzlato; Heleket; AlfaBit.org; Metka.cc; CoinBlinker.com; Hd-change.com; 60cek.net; FlashObmen.com; SkyCrypto.net; Nobitex.ir; Terminal.cash; Aifory.pro; Bixter; Nix Money; BitBits; Cripta; Crypto Cloud; exmo.me; exmo.com; Yobit; Freekassa; Web Money; Fun Pay; Vexel; 1xBet and all related entities; Meer.kg; payeer.com; Grinex.io; Stake.com; Samourai Wallet; AlphaPo; Bitpapa; Anonymix; WhaleAlert; Finiko; Suex; BTC-e; Capitalist; Commex; Sinbad.io; ChipMixer; Genesis Market; Lazarus Group; Blender.io; Hydra; Tornado Cash; Garantex; HTX (Huobi); Rapira.

This list covers high-risk platforms as well as platforms from countries subject to sanctions or other international restrictions. The service reserves the right to supplement and update this list without prior individual notice to users.

10. Final Provisions

LeoExchanger reserves the right to change, supplement, and update this Policy without prior individual notice to users.

By using the service, the user confirms that they have read this Policy, understand that an AML/KYC review may be carried out, and agree to provide the data required for such a review in the cases provided for by this Policy.

Last updated: August 10, 2026