Monetkins AML/CFT Policy

Update date: January 12, 2026

Basis: International FATF standards.

1. General Provisions

This regulation describes a set of security measures implemented on the Monetkins.com platform (hereinafter referred to as the "Service" or "Platform"), aimed at preventing money laundering and terrorist financing. This document has been developed in accordance with FATF recommendations and the regulations of the jurisdictions where the Service operates.

The main objectives of the Policy:

* Reducing the risks of illegal use of the Service infrastructure.

* Guarantee of regulatory compliance.

* Protecting Monetkins" business reputation and ensuring the trust of clients and regulators.

By registering on the platform, the user automatically agrees to the terms of this Policy, which forms part of the User Agreement.

2. Platform Obligations and Risk Management

Monetkins service undertakes the following key obligations:

• Implementation of KYC (customer identification) and KYT (transaction monitoring) procedures.
• Regular risk assessment of the client base and operations.
• Continuous payment monitoring to detect suspicious schemes.
• Blocking assets and suspending transactions when AML/CFT threats are identified.
• Transfer of data to government agencies in cases provided by law.
• Storage of transaction data and personal information for at least 5 years.
• Regular training of staff on compliance standards.
• Guarantee of the legality of transferred digital assets.

Cryptocurrency payout requirements

All outgoing transactions comply with FATF and OFAC regulations and are sent only to:

* Unique one-time addresses.

* Low-risk addresses (confirmed by AML systems).

* Wallets of licensed crypto exchanges.

3. User Identification (KYC)

Customer Identification and Risk Management Requirements

To remove restrictions on platform functionality, each client is required to undergo verification. Monetkins delegates the data verification process to accredited third-party KYC providers. Depending on the assigned verification level, corresponding withdrawal limits are set:

Level 1 (Basic) - Designed for users performing standard, low-risk transactions. Mandatory provision includes:

• email address;
• identity card;
• confirmation of residential address.

Level 2 (Advanced) - Applies to users with a high AML status or when indicators of increased risk are detected in transaction activity. The compliance service has the right to request an expanded package of documents, including:

• email and identity verification;
• verification of residence address;
• information about the source of capital formation (Source of Funds).

The criteria for assigning a user to the second verification level, as well as the list of required documents, are determined by the service independently, based on the results of a risk analysis for each specific case.

List of documents

1. a) Identity card

Must be valid and contain a photo, full name, date of birth, and relevant information. Latin transliteration is required.

* Internal passport;

* International passport;

* Driver license.

1. b) Proof of address (not older than 3 months)

* Lease agreement or bank statement;

* Housing and communal services receipts;

* Tax return;

* Other official papers with address (within 90 days).

Important: Latin transliteration is required.

1. c) Photo verification

A selfie of a customer holding a sheet of paper with "Monetkins.com" and the current date written on it.

Inspection regulations

* The platform reserves the right to refuse service if there are doubts about the veracity of the data.

* Checks are ongoing; for suspicious accounts, the frequency of checks increases.

*Documents may be requested again at any time.

* Prohibition : Users from sanctions lists (FATF, OFAC, EU, UN) and the Appendix No. 1 list are not served.

Requirements for documentary justification of sources of funds (SoF)

As part of measures to combat illegal financial transactions, during advanced verification, the Client is required to confirm the legal origin of their funds. Acceptable documents include, but are not limited to:

• confirmation of employment income (income certificates, contracts);
• tax accounting documents (declarations);
• statements from financial institutions on receipt of funds;
• evidence of income from capital management (dividends, investments);
• contracts for the alienation of property (movable or immovable);
• documents confirming inheritance rights;
• gift agreements;
• reporting of business income;
• any other documents verifying the legal source of funds.

The Company reserves the right to determine the sufficiency of the documentation provided and to request additional materials depending on the current risk assessment and the specific situation.

Review periods:

* Standard verification: 1–24 hours.

*Enhanced Determination (EDD): 24–72 hours.

4. Monitoring of transactions (KYT)

Transaction analysis is carried out automatically and manually using specialized systems (for example, AMLBot).

Analysis criteria:

1. Connections to sanctions lists, darknet, fraudulent clusters.
2. Use of mixers and anonymization tools.
3. Suspicious patterns (smurfing, abnormal volumes, new wallets, risky jurisdictions).
4. Risk rating assignment: Low / Medium / High.

Risk scale

Status:	Risk range (according to provider):
Low	Up to 62%
Medium	From 62% to 72%
High	From 72% to 75%

Transactions with High Risk status may be blocked and referred to an AML officer. We recommend that you conduct checks yourself before sending a transaction to the exchange service and make sure that the address does not contain a risk. Our verification is carried out based on AML bot processing.

Address verification is available via: https://www.bestchange.com/report/

5. Classification of clients by risk

Depending on the risk profile, different client classification procedures are applied:

* Low risk: Standard check (CDD). Recheck on schedule.

* Medium risk: Enhanced monitoring. Re-check at least every 2 years.

* High risk: EDD procedure (source of funds inquiry, history analysis, annual KYC update). Re-verification annually.

Automatic high risk is assigned:

1. PEP (politically exposed persons and their entourage).
2. Residents of countries from the FATF High-Risk list.
3. For clients with turnover > $100,000 per year.

6. Incident response

If there are signs of money laundering or terrorist financing, Monetkins operates according to the following algorithm:

1. Stop transaction.
2. Account blocked until investigation is completed.
3. Creation of an internal report (SAR/STR).
4. Notification of regulators (Rosfinmonitoring, FinCEN, EU FIU, etc.) if there are grounds for doing so.

User"s refusal to verify will result in termination of service.

Commission policy for AML cases

* Refund fee: up to 5% of the amount (maximum $100).

*Exception: Refund is not possible if the assets are deemed illegal or subject to seizure by authorities.

* Legitimate clients: If no laundering connection is confirmed after KYC/SoF, only the blockchain network fee is charged.

7. Corporate compliance and partners

Requirements for counterparties:

* Prohibition on working with platforms from weak jurisdictions.

* Due diligence of partners (exchanges, gateways, API).

* Availability of licenses and compliance with AML/CFT standards by counterparties.

Domestic policy:

* AML Officer has been appointed (contact: [email protected]).

* Employee training – annually.

* Internal compliance audit – quarterly (external consultants may be involved).

8. Data protection

Personal data and transaction history:

1. Encrypted according to industry standards.
2. Stored on secure servers (GDPR and MiCA compliant).
3. Access is strictly limited to authorized personnel.
4. The storage period is at least 5 years after the end of cooperation (unless otherwise specified by law).

The Privacy Policy for the website and application is published separately.

9. Final Provisions

Monetkins reserves the right to unilaterally update this Policy by notifying users on the website. The current version is available at Monetkins.com.

Contact for incident reports: [email protected]

Responsible compliance officer: [email protected]

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Appendix No. 1

List of prohibited jurisdictions (High AML risk):

Residents and transactions related to the following territories are not accepted for service:

* Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma).

* Any territories subject to FATF, OFAC, EU and UN sanctions at the time of the transaction.

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© Monetkins.com, 2026