AML Policy

 

1obmen.net AML/KYC Policy

This Anti–Money Laundering (AML) and Know Your Customer (KYC) Policy (the “AML/KYC Policy”) is designed to prevent and reduce the risk of 1obmen.net being involved in unlawful activity, including money laundering, fraud, and terrorist financing.

Terms and definitions

Services — operations for exchanging digital (electronic) currencies carried out on the Website: 1obmen.net.
User — any person using the Website’s functionality. The User confirms they are 18 years old or older, the use of the service is not prohibited by the laws of their country of residence, and they will not use the Services for unlawful purposes.
Administration — authorized representatives of the service acting on behalf of the Website: 1obmen.net.
Personal data — any information relating to an identified or identifiable natural person, directly or indirectly.
Request — a User’s request to buy/sell digital (electronic) currencies using the Services, submitted via the Website.

1. Purpose of internal regulation

1.1
General AML principles. The service 1obmen.net implements AML measures and follows the principle of preventing the platform from being used for illegal purposes.
1.2
Risk-based approach (Risk-based AML). The service applies a risk-based model: each Request and/or transaction may be subject to automated and/or manual checks. The scope of checks and the requested information depend on the risk level and additional triggers.
1.3
Risk Score logic. Risk is assessed using a combination of factors, including (but not limited to): links to sanctioned/high-risk entities; indicators of illegal activity, fraud, or stolen funds; use of obfuscation/mixing and complex chains; anomalies in transaction structure (including splitting/structuring — “smurfing”); inconsistencies in User data, sending/receiving addresses, geography, and behavioral patterns.
1.4
Thresholds and decisions. If risk reaches or exceeds internal thresholds (e.g., 50%), the service may suspend the transaction, request additional information (KYC/SoF), refuse service, or initiate a refund in accordance with this Policy and applicable requirements. The threshold value is provided as an example and does not guarantee outcomes for any specific transaction.

2. Warning

2.1
The service 1obmen.net warns against using the Website to legalize criminal proceeds, finance terrorism, commit any type of fraud, or purchase/provide prohibited goods and services. The Website, its Administration, staff, and domain owners are not liable for unlawful use by third parties, malicious actions, or potential damage related to the use of the Website, to the extent permitted by applicable law.

3. Requirements

3.1
To prevent illegal operations, the Website establishes requirements for all Requests submitted by the User:
3.1.1
The payer and the recipient under a Request must be the same person. Transfers to third parties using the Website’s Services are prohibited. If there are signs of third-party involvement (including where the actual sender differs from the User), the service may suspend the operation, request additional data/documents (including those listed in Section 4), refuse service, and/or issue a refund in accordance with this Policy and applicable requirements.
3.1.2
All contact details entered by the User in a Request, as well as any other Personal data provided to the Website, must be accurate, current, and valid.
3.1.3
Creating Requests using anonymous proxy servers or other anonymous means of connecting to the Internet is prohibited.
3.1.4
The service does not recommend splitting/structuring funds from one wallet into multiple Requests (“smurfing”). Such behavior may be treated as suspicious and lead to suspension/blocking, even if previous operations from that wallet were not restricted.

4. Verification procedures

4
Customer due diligence (the “Check”) is one of the international standards for preventing illegal activity. For this purpose, the Website implements AML procedures and the “Know Your Customer” approach.
4.1
Proportionality principle. The service follows proportionality: the higher the risk, the broader the set of data and documents that may be requested. Requests may include identity verification and/or confirmation of Source of Funds (SoF).
4.2
The service 1obmen.net may require the User to provide reliable, independent documents/data/information for verification and confirmation of the source of funds. This may include:
  • a photo of an identity document (passport or national ID), all sides, in good quality;
  • a photo of the User holding the document (selfie), in good quality;
  • proof of employment status (if applicable);
  • a scan or photo of the passport (first, second pages, and registration page if available), in good quality;
  • proof of source of funds (photos, screenshots, statements);
  • a video where the sender holds an open passport (clearly showing the photo and full name) and states that they created the Request (ID/number) at 1obmen.net, that the sent funds are their personal property, and that they bear full legal responsibility for the cryptocurrency; the video must also mention the source of funds;
  • a video recorded from the platform where the funds were sent: the hash, sender and recipient addresses, amount with ticker, and transaction date must be visible; minimum duration — 10 seconds.
4.3
KYC/SoF request triggers (examples). Verification and/or SoF confirmation may be requested if: risk is above internal thresholds (e.g., Medium/High); high-risk categories or suspicious behavior are detected; splitting/structuring (“smurfing”) is identified; inconsistencies exist in User/transaction parameters; additional checks are required by an infrastructure partner (if applicable).
4.4
The service does not support transactions with a risk score of 50% and above in the following high-risk categories: illegal service, mixing service, fraudulent, exchange, darknet marketplace, darknet service, ransom, scam, stolen coins, terrorism financing, sanctions, illicit actor/organization, high-risk jurisdiction, gambling, fraud shop, enforcement action, child exploitation. Category names may follow the terminology of the AML analytics provider used.
4.5
In case of restrictions due to high risk, suspicious activity, or an official investigation, funds may be held until verification is completed or the investigation ends. For these purposes, the Website reserves the right to collect identifying information necessary to comply with this AML/KYC Policy.
4.6
The service takes steps to confirm the authenticity of documents and information provided by Users. Lawful methods may be used for additional checks, and the Website reserves the right to investigate cases classified as dangerous or suspicious.
4.7
The service may perform repeated/ongoing identity verification, especially if identification information changes or activity appears atypical. The service may request updated documents even if the User has verified previously.
4.8
User identification information will be collected, stored, transferred, and protected in accordance with the Website’s Privacy Policy and applicable regulations.
4.9
After confirming the User’s identity, the Website may refuse to provide Services if the Services are used for illegal activity.
4.10
The service may request confirmation of the source of financial funds or crypto-assets to ensure that the sources used by Users are lawful.
4.11
The service may choose not to disclose the reason for a transaction restriction.

5. Responsible officer

5
The person responsible for AML compliance is an individual duly authorized by the service, whose role is to ensure effective implementation and adherence to this AML/KYC Policy.
5.1
The responsibilities of such officer include, but are not limited to:
  • collecting Users’ identification information;
  • developing and updating internal policies and procedures;
  • monitoring transactions and investigating material deviations from normal activity;
  • maintaining document/file/form/log storage and retrieval systems;
  • regularly updating risk assessments;
  • providing information to law enforcement authorities when required by law.
5.2
The responsible officer may interact with law enforcement authorities involved in preventing money laundering, terrorist financing, and other illegal activity.

6. High-risk services and self-check recommendations

6.1
Examples of high-risk services/entities. High-risk entities may include (non-exhaustive): WEX Exchange, Yolo Group, Black Sprut, BTC-e, ChipMixer, Bitpapa, NetEx24, Bitzlato, DoubleWay, MEGA DARKNET MARKET, Garantex, 1xBit, Stake, Primedice, OMGOMG, DuckDice, Payeer, Wasabi Wallet, Gandhiji.io, Hydra, NVSPC, Roobet, Tornado Cash, DuelBits, FreeBitcoin, Darknetone, Commex, Trocador, Anonexch, Shinbad.io, Genesis Market, Lazarus Group, Cryptomus and others.
6.2
⚠ Transfers via Rapira and Capitalist are not supported and will be rejected.
6.3
Risk lists and criteria may be updated without prior notice.
6.4
Before sending funds, we recommend checking addresses and assets using AML analyzers. This helps assess the origin of funds and reduces the likelihood of restrictions by third-party services.
6.5
We recommend that users check their addresses and assets via specialized AML analyzers before sending funds. This helps verify the origin of funds and reduces the likelihood of potential restrictions by third-party services.
You can also use the BestChange monitoring check:
BestChange:
https://www.bestchange.ru/report/
Checking cryptocurrency before an exchange is an additional safety measure and care for the security of your funds.

7. Behavioral analysis

7.1
The service 1obmen.net checks Users not only through identity verification but also through behavioral analysis in transactions. Such analysis is used as a risk assessment tool and to detect suspicious activity.

8. Risk assessment

8.1
The Website applies risk assessment practices to combat money laundering and terrorist financing. Using a risk-based approach, the service ensures measures are proportionate to identified risks.

9. Conducting user checks

9.0
If the Administration has reasonable suspicion that a User is attempting to use the Services for money laundering or other unlawful activity, the Administration may:
  • monitor transaction chains to identify suspicious transactions;
  • suspend an exchange operation for the duration of the investigation (up to 7 business days; in special cases — up to 30 business days);
  • request identity verification documents from the User;
  • request additional information and documents in case of suspicious transactions;
  • ensure reporting of suspicious deals to competent authorities through the responsible officer (if applicable).
9.1
Typical steps and indicative timelines. A typical AML case may include: automated screening (minutes); initial manual review (up to 24 hours); KYC/SoF request (if needed) and waiting for the User’s response; review of submitted materials (usually 1–5 business days); final decision (typically up to 7 business days total; in special cases — up to 30 business days).
9.2
Following the review, the Administration decides to proceed with the exchange or issue a refund (minus network/payment system fees for sending, and a refund processing fee if applicable).
9.3
Proportionality of fees on refunds. If the User has passed verification and/or there are no sufficient grounds to consider the transaction suspicious, deductions are limited to the network/payment system fee only (without “penalty” deductions). A refund processing fee may be up to 4% of the exchange amount, but not more than 100 USD (or equivalent), and may be charged only in AML cases where the service incurred documented costs.
9.4
A refund or exchange (if approved) will be processed by the Administration within 7 (seven) calendar days from the date the User is notified of the decision regarding the request.
9.5
If an exchange is approved after AML analysis, the rate may be recalculated to the current market rate regardless of the selected tariff.
9.6
When issuing a refund or exchange after completing the check (verification), the User must confirm the details required to receive the refund or exchange funds.
9.7
If a User’s transaction becomes the subject of interest of law enforcement authorities, the investigation period may be unlimited.

10. Confidentiality

10.0
The service 1obmen.net ensures User confidentiality in accordance with the Website’s Privacy Policy.
10.1
The Website and its employees must keep confidential any facts identified in connection with any suspicious transaction. This obligation also applies to Users and third parties who receive transaction-related information, to the extent required by applicable law and/or contractual obligations.
10.2
The confidentiality obligation remains in force after termination of employment or other contractual relationships with the service, or when staff are transferred to another position. Disclosure to government and law enforcement authorities and other parties in cases defined by law is not considered a breach of confidentiality.
10.3
Confidentiality restrictions do not apply to information sharing between financial institutions forming a consolidated group (if any), provided such information is used solely for preventing money laundering and terrorist financing.

11. Conclusion

11.1
In view of the above, the service 1obmen.net does not bear legal responsibility for attempts to use it to legalize criminal proceeds, finance terrorism, or purchase prohibited goods and services, but undertakes to take all reasonable and available actions to prevent unlawful use, within the limits permitted by applicable law.
11.2
By performing an exchange, the User agrees to all terms of this AML/KYC Policy and undertakes to comply with them in accordance with the service rules in effect at 1obmen.net

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