This AML Policy governs Top-changer.com’s actions in the fight against money laundering and terrorist financing.
Terms and Definitions
Top-changer.com is a brand of a platform that provides users with the opportunity to exchange digital and electronic currencies. The service is a system for providing Internet services for the exchange, sale and purchase of digital and/or electronic currencies. User – any individual using the services of the Top-changer.com service. Digital currency is Bitcoin, Litecoin, Ethereum and other currencies based on blockchain technology. Electronic currency is funds in the accounts of users of electronic payment systems. Service services – assistance in conducting transactions between individuals for the purchase and sale and exchange of digital currencies, as well as other services presented on the Service showcase. Card verification is a procedure for verifying that a card (or account) belongs to its owner. It is carried out once for each new account (card) of the User. Money laundering is the process of legalizing illegally obtained funds. Top-changer.com strictly adheres to laws prohibiting involvement in money laundering or terrorist financing. Terrorist financing is the provision or collection of funds with the purpose of using them to finance terrorist acts.
Measures to Comply with the AML Policy
The administration of Top-changer.com has developed a set of measures in accordance with national legislation and FATF requirements to combat money laundering and terrorist financing. European AML regulation includes the Sixth Anti-Money Laundering Directive (6AMLD), which came into force in 2018. In addition, there are other legislation aimed at combating money laundering and terrorist financing.
Fifth Anti-Money Laundering Directive (EU) 2018/843; Proceeds of Crime Act 2002; Terrorism Acts 2000 and 2001; Anti-Terrorism Act 2008; Treasury Sanctions Notices.
Application of KYC (“know your customer”) policy. Mandatory identification of users who are allowed to conduct transactions on our service. To verify a user account, the administration has the right to request the following data: take a photograph (“selfie”) with an identification document: a scanned copy of the front and back of a valid passport, driver’s license or other identification card with a photo; confirm place of residence: an official document issued within the last 3 months containing the name and address of the client specified when registering on the Top-changer.com website, for example, utility bills or bank statements; provide a copy of the front and back sides of the bank card and/or a photo of the bank card in the background of the main page of the service. To ensure privacy and security, only the last 4 digits of the credit card are visible.
The administration of the Top-changer.com service verifies the authenticity of the provided documents and user information. Identity checks are also conducted through secondary sources and additional investigations are conducted if necessary.
The administration of the Top-changer.com service can continuously monitor user operations, especially when identification information changes or suspicious activity occurs. Users may also be asked to provide additional documents.
To ensure compliance with the Policy, a responsible person (MLRO – Money Laundering Reporting Officer) is appointed on the site.
A risk-based approach (RBA) is used, including varying levels of verification depending on the volume and nature of the user’s transactions.
Top-changer.com team members regularly improve their professional skills and knowledge in the field of compliance with the requirements of the Policy.
Interaction with government agencies is carried out in accordance with the law. If we receive an official request from law enforcement or judicial authorities, we are required to provide them with the requested information. In addition, if requested by official representatives of payment systems, the administration of the Top-changer.com service has the right to provide the requested data.
We are constantly improving the security of the Top-changer.com service software to ensure the reliability and safety of your transactions. Our IT department is constantly improving to protect the site from unauthorized access by intruders.
In cases provided for by law, the administration of the Top-changer.com service may require verification of the source of fiat money and/or cryptocurrency to ensure their legality. A bank statement or video of a cryptocurrency wallet transaction may be required to confirm the source of funds.
According to this policy, the service administration will:
monitor all transactions and report suspicious transactions to law enforcement agencies;
request additional information and documents from users in case of suspicious transactions or at the request of the regulator;
suspend or terminate user accounts if illegal activity is suspected.
This list is not exhaustive and the responsible official monitors user transactions on a daily basis to identify suspicious transactions.
Countries to which increased risk criteria apply in accordance with the AML/CTF policy are separately identified.
Various data sources are used for categorization:
Transparency International is an organization that analyzes corruption in various countries around the world.
Know Your Country is a platform that provides information about the political and economic situation in various countries.
FATF High Risk Jurisdictions List is a list of countries that the FATF (Financial Action Task Force) considers to be at high risk for money laundering and terrorist financing.
The EU High Risk Jurisdictions List is a similar list, but developed by the European uniоn.
Countries where digital assets are prohibited or have trading restrictions.
Countries that do not prohibit digital assets.
Countries subject to the UN Security Council sanctions regime.
All clients living in the countries listed above cannot be served on the Top-changer.com service. Service will be refused and any funds returned to the source.
The full list of prohibited jurisdictions includes countries such as
USA
Afghanistan
Albania
Angola
Algeria
Barbados
Bolivia
Botswana
Burma (Myanmar)
Burundi
Cambodia
Central African Republic
Chad
Congo
Conakry
Ivory Coast
Crimea, Ukraine)
Ukraine, only currency pairs prohibited by local legislation.
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 Top-changer.com takes strict precautions regarding clients from disputed territories. This is because such territories often do not provide generally recognized 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
This policy aims to comply with the principles of KYT (Know Your Transaction). In case of suspicion of illegal activity, such as money laundering or the use of funds with criminal origin, Top-changer.com has the right to identify the transaction client. The service can use various sources of information and analysis of the origin of funds to identify suspicious transactions. Any content of high-risk assets may be grounds for further investigation.
The Top-changer.com administration has every right to make decisions and take actions in the following cases:
Require the client to provide additional information about the origin of digital assets or confirmation of their legality.
Block the account and related transactions and transfer information to regulatory authorities if there is suspicion of illegal activity.
Request documents from the client to confirm identity, address and solvency.
Make refunds only to those details from which the transfer was made, or to others after a security check.
Refuse a client to withdraw funds to a third party account without giving reasons.
Hold client funds until the investigation of the incident is completed.
Monitor the chain of transactions to identify suspicious transactions.
Refuse services to a client if there are suspicions of the illegal origin of assets and keep funds in special accounts.
Refunds of funds frozen for verification based on the results of AML analysis are carried out after a security check with a commission of up to 5% of the transaction amount.
If a refund is approved, funds are processed within 7 calendar days with users notified of the decision and confirmation of details.
