AML/KYC

1.1. This AML/CFT Policy (hereinafter referred to as the “Policy”) defines the measures applied by the Mint-Change service to prevent money laundering and terrorist financing.

1.2. The Policy is a local regulatory document of Mint-Change and is mandatory for all employees involved in processing requests and conducting operations.

1.3. The Policy is developed in accordance with the risk-based approach, FATF recommendations, monitoring requirements, and applicable legislation.

1.4. Use of the Mint-Change service constitutes the user’s agreement with this Policy.

2.1. Mint-Change — trademark of a digital asset exchange service.
2.2. Service — the Mint-Change information system intended for providing digital asset exchange services.
2.3. User — an individual using Mint-Change services.
2.4. Digital Assets — cryptocurrencies and other blockchain-based digital currencies.
2.5. AML Check — automated verification of an address or transaction using AML analyzers.
2.6. Risk Score — final aggregated numerical indicator of transaction risk level.
2.7. KYT (Know Your Transaction) — transaction monitoring and analysis procedure.
2.8. SoF (Source of Funds) — procedure for confirming the source of funds.
2.9. KYC (Know Your Customer) — user identity verification procedure.
2.10. MLRO — responsible AML/CFT officer.

3.1. AML, KYT, SoF, and KYC functions are implemented within the Mint-Change internal Security Service.

3.2. The Security Service is responsible for analyzing AML reports and Risk Scores, interacting with users, documenting cases, and making operational decisions.

4.1. All incoming transactions undergo mandatory KYT checks using the Rapira AML analyzer.

4.2. Mint-Change does not manually adjust Risk Scores and does not use alternative risk models.

4.3. The final Risk Score is the primary determining risk assessment criterion. Risk tags are considered only as part of the overall evaluation.

4.4.1. The Risk Score is generated by the AML provider within a risk-based transaction assessment model.

4.4.2. The Risk Score is an aggregated numerical indicator calculated based on combined analysis of transaction parameters and related risk factors.

4.4.3. The Risk Score may take into account:

• history of digital asset movement and on-chain origin;

• presence and share of risk tags (including Scam, Dark Market, Enforcement Actions, etc.);

• nature, structure, and sequence of transactions;

• behavioral and temporal indicators of fund movement;

• other parameters used by the AML provider.

4.4.4. Risk tags are not applied independently and are considered only within the overall Risk Score.

4.4.5. Mint-Change does not influence Risk Score calculation and uses it as provided by the AML provider.

4.4.6. The final Risk Score determines the applicable transaction processing scenario.

5.1. Before creating an order, users may conduct a preliminary AML check of a cryptocurrency address.

5.2. The functionality is available in the website header under “Check Wallet” and leads to:

https://www.bestchange.ru/report/

5.3. Preliminary checks may be conducted using paid AML analyzers provided by BestChange or third-party AML services.

5.4. Based on the preliminary check, the user may:

• provide results to the service operator for pre-assessment;

• or decline to provide results and accept potential risks, including transaction suspension.

6.1. KYT is applied by default to all incoming transactions to generate Risk Score and determine additional controls.

6.2. Additional control procedures may be triggered by:

• Risk Score above 60%;

• high share of risk tags;

• lack of explanation of funds origin;

• use of anonymous communication channels;

• other regulatory risk factors.

6.3. SoF procedure is applied first to confirm the source of funds without user identification.

6.4. Within SoF, the user may provide explanations, transaction hashes, links, statements, screenshots, and other materials not containing personal data.

6.5. If sufficient explanation is provided, KYC is not applied.

6.6. KYC is applied only when SoF confirmation is insufficient or risk level requires identification.

6.7. Mint-Change requests only information relevant to KYT, SoF, or KYC procedures.

• transaction is temporarily suspended;

• user is requested to provide SoF explanations;

• if SoF is insufficient, KYC may be requested.

The service may request:

• identity document;

• photo or video of the user holding ID and a paper with order number/date;

• video confirming conscious transaction creation;

• Source of Funds explanation;

• proof of income or professional activity (if required);

• additional supporting materials (statements, screenshots, confirmations).

Requests are based on sufficiency and proportionality principles.

6.10. KYC verification may take up to 7 business days after receiving all required documents.

7.1. If Risk Score exceeds 60%, Mint-Change may suspend transaction processing until checks are completed.

8.1. Following AML checks, Mint-Change may complete exchange, return funds, or refuse service.

8.2. In case of refund, Mint-Change may charge up to 5% (maximum 100 USDT).

8.3. Good-faith users whose funds are not linked to illegal activity receive refunds without additional fees except blockchain fees.

8.4. Refunds are processed within up to 10 business days after completion of AML/KYC checks.

Mint-Change does not provide services to users connected with high-risk jurisdictions according to FATF and sanctions lists.

Services are not provided to users from the following jurisdictions (funds returned where legally possible):

USA, Afghanistan, Albania, Angola, Algeria, Barbados, Bolivia, Botswana, Myanmar, Burundi, Cambodia, Central African Republic, Chad, Congo, Guinea, Ivory Coast, Cuba, North Korea, Ecuador, Egypt, Equatorial Guinea, Eritrea, Ghana, Guinea-Bissau, Haiti, Guyana, Iran, Iraq, Laos, Lebanon, Libya, Mali, Morocco, Nepal, Nicaragua, North Macedonia, Pakistan, Panama, Qatar, Saudi Arabia, Somalia, South Sudan, Sudan, Syria, Tunisia, Uganda, Vanuatu, Venezuela, Yemen, Zimbabwe, Jamaica.

Restricted sources of funds:

• WhiteBit

• HODLHODL

• Grinex

Mint-Change may update jurisdiction lists without prior notice.

10.1. AML data is stored in a secure internal environment with restricted access.

10.2. Upon official requests, Mint-Change provides information in accordance with applicable legislation.

11.1. Mint-Change may amend this Policy to comply with monitoring and legal requirements.

11.2. Updated Policy versions become effective upon publication on the Mint-Change website.