AML,KYC,SoF regulations

1. Risk Assessment

The CryptoGin service conducts mandatory AML checks on all incoming transactions using the blockchain analytics system of the professional blockchain analysis provider BitOK. In addition, a Risk Score system is applied based on analytical data obtained from the BitOK platform.

By using the service, the User agrees to undergo the KYC verification procedure. Identity verification is carried out through the licensed compliance service provider SumSub, which acts as the official service provider. Personal data processing is performed in accordance with the current Personal Data Processing Policy of the SumSub Service.

Following the AML check, each transaction is assigned the following indicators

- Overall Risk Score, expressed as a percentage;

- Category Risk levels, also expressed as percentages.

Transaction processing is permitted provided that the Overall Risk Score does not exceed 70%, and the category risk indicators do not exceed the maximum allowable thresholds specified below.

The service allows minimal risk values across certain categories, as blockchain transactions may contain technical traces (dust) or transit connections that do not necessarily indicate direct involvement of the user in illicit activities.

If the Overall Risk Score or any category-specific risk exceeds the установленный threshold, the service reserves the right to suspend the processing of the request, request additional information and/or documents (including verification), and/or refuse to execute the exchange operation.

Risk categories and maximum allowable thresholds

Gambling - 50%

Darknet Marketplace - 3%

Darknet Service - 3%

High-Risk Jurisdiction - 3%

Illicit Actor/Organization - 3%

Illegal Service - 3%

Enforcement Action - 3%

Mixing Service - 3%

Sanctions - 3%

Scam - 3%

Stolen Coins - 3%

Fraudulent Exchange - 3%

Ransom - 0%

Child Exploitation - 0%

Terrorism Financing - 0%

Funds associated with the infrastructure services of WhiteBit / W Group (including affiliated entities), if their origin is identified, may be subject to temporary restriction measures (freezing) or full blocking.

2. Procedure for KYC/SoF verification

In the event of an Order being suspended following an AML check, the service has the right to request identity verification and/or proof of source of funds (KYC/SoF) through the SumSub service.

List of documents that may be requested for KYC / SoF verification:

- Identity document: passport, ID card, or driver’s license;

- Selfie / Liveness check: a real-time photo or video of the face (following the SumSub system instructions);

- Proof of address: one of the documents issued within the last 3 months (utility bill, internet/phone bill, bank statement, official letter from a government authority). The document must include the client’s full name, complete address, and match the details on the identity document;

- Proof of source of funds – if required. Depending on the Risk Score, the following may be requested: screenshots of exchange/wallet accounts, transaction history, income verification (salary, dividends, freelance, etc.), asset sale agreements, as well as other documents confirming the legal origin of funds.

Procedure:

1 Suspension of application processing.

2 Sending the User a request to complete identity verification and/or confirm the source of funds (KYC/SoF).

3 Waiting for the User to provide the requested materials.

4 Receipt and review of the submitted documents, or recording the User’s refusal to provide them.

* In the event that digital currency is blocked by an external platform, the review period may be extended and will depend on the review conducted by the relevant wallet, platform, or other counterparty.

5 Making a decision to resume application processing, refund the digital currency, or refuse to carry out the transaction.

3. Return of digital currency depending on verification results

3.1 Return upon Confirmation of User’s Good Faith

If, following KYC/SoF verification, no connection of the digital currency with money laundering, criminal activity, illegal operations, and/or other prohibited sources is identified, the service will return the digital currency or complete the processing of the Order.

In the case of a return, only the blockchain network fee is charged. The CryptoGin service does not charge any additional fees.

3.2 Return when verification (KYC/SoF) cannot be completed

If the user fails to provide sufficient information and/or documents for identity verification and/or proof of source of funds (KYC/SoF), including cases of refusal to undergo verification, the service has the right to deny the exchange operation and decide on the return of the digital currency.

In this case, the return is made with a fee of 5% of the received amount, but not exceeding 100 USD in the equivalent of the received currency.

3.3 Return in case of funds blocked by external platforms

If a global regulator and/or other regulatory authority, trading partners, custodial service (including at the request of law enforcement), and/or payment system blocks or freezes the funds, the return can only be made after the funds are fully unblocked by the specified services, regulators, and systems.

In this case, the fee is applied according to this section and may be up to 5% of the amount, but not exceeding 100 USD in the equivalent of the received currency.

3.4. Timeframes for AML/KYC/SoF procedures

The initial AML screening is performed automatically and takes up to 5 minutes.

Transaction review and the completion of KYC/SoF procedures may take from 1 to 3 business days, depending on the transaction risk level and the completeness of the data provided by the User. In certain cases, the review period may be extended if additional transaction analysis is required.

3.5. Refund Timeframes

The refund of digital currency is processed within 12 to 24 hours from the moment the refund decision is made.

An exception applies to the cases specified in clause 3.3 (Funds Blocked by External Platforms), where refund timeframes cannot be determined and depend on the actions of the receiving wallet, platform, or law enforcement authorities.

If no official request for the refund of digital currency is received by our security service within 90 calendar days, the digital currency shall not be subject to refund.

4. Terms of exchange

The CryptoGin service strictly warns users against using its services for laundering illegally obtained funds, financing terrorism, fraud in any form, as well as for purchasing prohibited goods and services.

To prevent illegal operations, the service establishes certain requirements for all Orders created by users:

- The sender and recipient of the payment in the Order must be the same person. Using the service to transfer funds to third parties is strictly prohibited;

- The user must provide accurate and up-to-date personal data when filling out an Order, as well as any other information submitted to the service.

If the service administration has reasonable suspicions that a user is attempting to use the service for money laundering or other illegal operations, the administration has the right to:

-temporarily suspend the user’s operation;

- request documents from the user confirming their identity;

-request additional information related to payments.

4.1 Disclosure of Client Information

All information provided by the client may be disclosed to regulatory authorities in the following cases:

- at the request of law enforcement agencies;

- in accordance with decisions of courts in various jurisdictions;

- at the request of payment system administrations.

5. Rights of the service

The service reserves the following rights:

- To require the user to provide additional information disclosing the origin of digital assets and/or confirming that these assets were obtained legally;

- To block the user’s account and all associated operations, and to transfer information and documents regarding the case to financial regulatory authorities and/or law enforcement agencies, in accordance with the service’s jurisdiction and, if necessary, the user’s place of registration;

- To require the user to provide documents confirming identity, conduct video verification, registration address, and solvency;

- To return digital assets only to the account from which the transfer was made, after full verification by the service’s Security Department, if the legal origin of the client’s funds can be confirmed;

- To refuse a user’s withdrawal of funds to a third-party account without explanation;

- To freeze the user’s funds until a full investigation of the incident is completed;

- To monitor the entire transaction chain to detect suspicious operations;

- To refuse the user service if there are reasonable suspicions about the illegal origin of digital assets or when it is impossible to trace the full chain of asset movement from the moment of their origin, and to hold funds in the service’s special accounts;

- To reserve the right not to disclose information about the methods and results of verifying the user’s transactions.