AML/KYC Policy

Introduction

The BUYBank service adheres to practices and measures in the field of counteracting the legalization (laundering) of funds from crime, funds for the financing of terrorism that fall under the AML (Anti-Money Laundering) policy.

Purpose of internal regulation

The purpose of these measures is to prevent and reduce the possible risks of the BUYBank service being involved in any illegal activity.

Our internal control policy provides for the application of the necessary measures and technologies to provide our Users with the most secure and high-quality services.

The AML/KYC policy covers the following procedures:

• transaction monitoring;
• risk assessment;
• verification procedure.

Transaction monitoring

The BUYBank service relies on data analysis as a risk assessment and suspicion detection tool. In this regard, the Service reserves the right to analyze the User's Applications, his transactions when interacting with the Service, as well as the chains of transactions preceding them, in order to identify suspicious transactions.

Risk assessment

BUYBank, in accordance with international requirements, checks transactions for risk using specialized AML services.

The cryptocurrency sent by the client undergoes an AML check for the purity of the asset. In case the transaction is considered high-risk, the Service may refuse to provide the User with services, while the funds will be frozen until the circumstances are fully clarified, the KYC procedure is completed and the source of the asset is identified. Immediately after that, the transferred funds will be returned minus the commission.

Operations with a total Risk Score above 50% are considered high-risk, as well as if the Risk Score exceeds 1.5% in the following categories:

• Dark Service — coins associated with child abuse, terrorist financing or drug trafficking;
• Dark Market — coins that were used for purchases on the dark web;
• Scam — coins that were obtained by deceiving their customers;
• Mixer — coins have been run through a mixer to make them difficult or impossible to track. Often used for money laundering;
• Illegal Service — coins associated with illegal activities;
• Ransom — coins obtained through extortion or blackmail;
• Exchange Fraudulent — coins from the exchange associated with fraud, illegal activities, or whose funds have been seized by the government;
• Stolen — stolen coins;
• Gambling — coins associated with online casinos without a license;
• Sanction — funds associated with countries - terrorists or financing terrorism.

We would like to draw your attention to the fact that usually the User's funds are frozen on exchanges and other custodial wallets where the Service accepts funds. In this case, the Service relays the requirements of the exchange to the User. The Service cannot process the Application or make a refund while the funds are frozen and awaiting a decision from the exchange, its security department or other regulatory or law enforcement agencies.

If the User refuses to provide the necessary information, the Service relieves itself of obligations and liability for the execution of the Application and the return of funds to the User.

Verification procedure

One of the international standards for preventing illegal activity is KYC customer due diligence - Know Your Customer.

If reasonable suspicions arise from the administration of the BUYBank service that the User is trying to use the services of BUYBank for money laundering or for the purpose of carrying out any other illegal operations, the administration has the right:

• suspend the execution of the User's Application;
• request from the User identification documents, a selfie with this document and a sheet on which the current date and signature will be written by hand;
• request from the User a video with the entrance to the wallet, where the last incoming and outgoing transactions to the address provided by the Service will be visible;
• request from the User additional information disclosing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
• block the account and any operations related to the User;
• refund funds only to the address(wallet) from which the transfer was made;
• refuse the User to withdraw funds to the accounts of third parties without explanation;
• hold the User's funds until the incident is fully investigated;
• ask the User for up-to-date documents, even if he was identified in the past;
• refuse the User to provide the service, incl. after confirming the identity of the User.

The User undertakes to provide only truthful information and original documents. At the same time, the BUYBank service is not authorized and is not obliged to establish the fact of their authenticity, but it can conduct an additional check, and in case of obvious inconsistencies in the information received, it has the right to require additional documents from the User to identify his identity and the origin of funds. If the User refuses to provide the required information when necessary, or tries to mislead the Service, this User may be denied the provision of services.

User identification information will be collected, stored, shared and protected strictly in accordance with the Service's Privacy Policy and related rules.

Warning

The BUYBank Service warns users against attempts to use the Service to legalize money obtained by criminal means, financing terrorism, fraud of any kind, as well as from using the Service to purchase prohibited goods and services.

All information provided by the client may be transferred to the relevant authorities in the following cases:

• at the request of law enforcement agencies;
• by decision of courts of different instances;
• at the request of the administrations of exchanges or payment systems.

Requirements

To prevent operations of an illegal nature, the Service establishes certain requirements for all Applications created by the User:

• The sender and recipient of the Payment under the Application must be the same person. Using the services of the Service, transfers in favor of third parties are strictly prohibited.
• All contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely reliable.
• It is strictly forbidden to create Applications by the User using anonymous proxy servers or any other anonymous Internet connections.
• The service reserves the right to block funds from exchanges that are included in the sanctions lists or have received the status of "high-risk".  

Conclusion

In connection with the foregoing, the BUYBank service does not bear any legal responsibility for using it for the purpose of laundering proceeds from crime, financing terrorism or purchasing prohibited goods and services, but undertakes to take all possible and available actions to prevent attempts to use the BUYBank service for the purpose of money laundering, terrorism financing or the purchase of prohibited goods and services.