AML and KYC policy

This AML Policy (hereinafter the Policy) governs the activities of 111obmen.com in combating money laundering and its involvement in combating money laundering and terrorist financing.

Terms and definitions. 111obmen is the trademark of a system that enables Users to exchange digital and electronic currency.
Service — a system providing online services for the exchange, sale and purchase of digital and/or electronic currencies.
User — any individual using the services of 111obmen.com.
Digital currency — Bitcoin, Litecoin, Ethereum and any other blockchain-based currencies.
Electronic currency — funds held in the accounts of users of electronic payment systems (Qiwi, Yandex.Money, etc.).
Services — assistance with p2p transactions between individuals for buying, selling and exchanging digital currencies, and other services described on the Service's storefront.
Card verification — confirmation that a card (or account) belongs to its holder. The Service sets the verification conditions; it is carried out once for each new account (card) of the User.
Money laundering — giving a legitimate appearance to the possession, use or disposal of funds or other property obtained through crime. 111obmen.com strictly follows the laws that prohibit us or any of our employees from knowingly engaging or attempting to engage in any activity related to money laundering. Our anti-money laundering policy aims to increase the security of clients and of the services provided by the Service.
Terrorist financing — the intentional provision or collection of funds by any means, directly or indirectly, with the intention that they be used, or in the knowledge that they will be used, to commit terrorist acts.

Measures taken to comply with the AML Policy

The administration of 111obmen.com, aware of the public danger of crimes related to money laundering and terrorist financing, has developed a set of organisational and legal measures to comply with national law and the requirements of the intergovernmental organisation FATF.

European AML regulation is based on a number of directives. In particular, the EU issued the Sixth Anti-Money Laundering Directive (6AMLD), which came into force on 2 December 2018.

Other legislation aimed at combating the legalisation of criminal proceeds and terrorist financing includes:

5th Anti-Money Laundering Directive ((EU) 2018/843);

Proceeds of Crime Act 2002;

Terrorism Acts 2000 and 2001;

Counter-Terrorism Act 2008;

Treasury sanctions notices;

Application of the KYC (know your customer) policy.

Mandatory identification of Users allowed to transact on our Service

To verify a User, the Administration may require the following:

• 1. a photo (“selfie”) with an identity document: a scan of the front and back of an official photo ID, i.e. a valid passport, driving licence or other national identity card;
• 2. proof of address: an official document issued within the last 3 months clearly showing the client's name and the address given when registering on 111obmen.com. This may be a utility bill (water, electricity or landline) or a bank statement. The copy must include: full name, full residential address, date of issue (within the last 3 months), the name of the issuing body with its official logo or stamp;
• 3. a copy of the front and back of the bank card and/or a photo of your bank card taken against the Service's home page (the storefront). For privacy and security, only the last 4 digits of your card should be visible. You may cover the 3 digits on the back of the card (CVV code).

The administration of 111obmen.com will take steps to confirm the authenticity of the documents and information provided by Users. Identification information will also be checked against secondary sources, and the administration reserves the right to continue investigating cases to be fully certain of the authenticity of the documents provided.

The administration of 111obmen.com reserves the right to monitor User data on an ongoing basis, especially when identification information has changed or activity appears suspicious (unusual for the particular User). The administration also reserves the right to request current documents from Users even if they have passed verification in the past. Ongoing monitoring of operations passing through the Service: we continuously monitor all orders created on 111obmen.com.

The administration notifies Users that third parties are prohibited from carrying out exchange operations using their account. A responsible officer (MLRO — Money Laundering Reporting Officer) is appointed to oversee compliance with this Policy. A risk-based approach (RBA) is applied.

The Service applies an automated transaction risk model (Risk Score) based on analysis of the source of digital assets and behavioural factors.
The risk score ranges from 0 to 100 points.

Depending on the risk level, the following measures apply:
— 0–50 (low risk): operations are executed as usual;
— 50–70 (medium risk): the Service may request additional information or documents;
— 70+ (high risk): the operation is suspended until KYC (identity verification) and/or SoF (source of funds) procedures are completed.

The thresholds may be changed by the Service without prior notice as part of its internal risk management policy.

We apply different levels of verification depending on the volume and number of operations carried out by the User. We raise the skills and knowledge of the 111obmen.com team regarding the Policy. We cooperate with state authorities where required by law. If we receive an official request from law enforcement or judicial authorities, we are obliged to provide the requested information. The administration may also provide data requested by official representatives of payment systems. We continuously improve the security of the 111obmen.com software.

We care about the reliability and security of your transactions. We continuously develop our IT team, whose main task is to protect the website from unauthorised access. Where required by law, the administration of 111obmen.com may require verification of the source of fiat money and/or cryptocurrency to make sure that the sources of the funds the Client uses for the exchange are lawful. A document confirming the source of funds may be a bank statement for fiat money or a video showing the transaction details in a cryptocurrency wallet.

The Service may additionally request:
— screenshots or videos from cryptocurrency wallets confirming ownership of the assets;
— the history of transactions (TXID) related to the receipt of funds;
— statements from cryptocurrency exchanges or other platforms;
— documents confirming the lawful origin of the funds (contracts, invoices, income statements, etc.).

Under this Policy the administration will:
— monitor all transactions. The administration reserves the right to report suspicious transactions to the appropriate law enforcement agencies through the Responsible Officer;
— request any additional information and documents from the User in the event of suspicious transactions, as well as at the request of a regulator (a regulator may be an exchange, a state institution or another organisation with the relevant legal grounds);
— suspend or terminate the User's account if there is reasonable suspicion that the User is involved in illegal activity. This list is not exhaustive, and the Responsible Officer will monitor User transactions daily to determine whether they should be reported and treated as suspicious or considered bona fide.

Procedure and timing of checks

The initial automated AML analysis of a transaction takes 5–60 minutes from receipt of the funds. If an elevated risk level is detected, the transaction may be suspended for additional checks. Additional checks (KYC/KYT/SoF) take from 1 to 7 business days from the moment the User provides all required data. In some cases the check may take longer if further investigation or interaction with third parties is needed.

Country of residence.

This Policy sets out our AML/CTF risk criteria. To reduce this risk, the administration of 111obmen.com does not accept clients residing in the following high-risk countries.

Sources used for categorisation: Transparency International; Know Your Country;

FATF list of high-risk jurisdictions;

EU list of high-risk jurisdictions;

Countries where digital assets are banned or trading is restricted;

Countries where digital assets are not banned;

Countries subject to UN Security Council sanctions.

All clients residing in the countries listed below are prohibited from using 111obmen.com and cannot be accepted as Users. Once it is established that a client belongs to these countries, service stops immediately. All funds received must be returned to the original source without exception.

Full list of prohibited jurisdictions:

Russian Federation
USA
Afghanistan
Albania
Angola
Algeria
Bangladesh
Barbados
Bolivia
Botswana
Burma (Myanmar)
Burundi
Cambodia
Central African Republic
Chad
Congo
Conakry
Côte d'Ivoire
Crimea (Ukraine)
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 111obmen.com also does not accept clients from disputed territories, as they do not issue generally recognised official documents, including:

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)
Republic of Kosovo
Sahrawi Arab Democratic Republic
Republic of Artsakh

KYT (Know Your Transaction) policy

The KYT (Know Your Transaction) policy aims to identify the client of a transaction when the Service has reasonable suspicion that the Client is misusing 111obmen.com. This may happen if the Service suspects the Client of illegal actions that may qualify as laundering or attempted laundering of digital assets obtained unlawfully, or the funds are of clearly criminal origin. For this purpose the Service may use any lawful information, third-party tools for analysing the origin of digital assets, and its own screening system.

To analyse transactions and assess risk, the Service uses specialised AML tools and blockchain analytics providers.
The results are used to calculate the Risk Score and make decisions on operations.

A preliminary AML check of a crypto address is available at https://www.bestchange.ru/report/.

In this case 111obmen.com reserves the full right to:

Require the Client to provide additional information disclosing the origin of the digital assets and/or confirmation that these assets were not obtained through crime;

Block the account and any operations related to the Client, and pass all available information and documents about the incident to the financial supervisory and/or law enforcement authorities at the Service's place of registration and, if necessary, at the Client's registered address;

Require the Client to provide documents confirming identity, physical existence, registered address and solvency;

Return digital assets only to the requisites from which the transfer was made, or to other requisites after a full check by the Service's security team, if the legal origin of the Client's funds has been verified;

Refuse the Client a withdrawal to a third-party account without giving reasons;

Hold the Client's funds until the incident has been fully investigated;

The Service reserves the right to monitor the entire chain of transactions to detect suspicious transactions;

The Service reserves the right to refuse service to the Client if it has reasonable doubts about the lawful origin of the digital assets and to hold the funds in the Service's special accounts. The cryptocurrency may be seized by the Service after an AML investigation, including in favour of law enforcement agencies.

The Service reserves the right to refuse service to the Client if it has reasonable doubts about the lawful origin of the digital assets and to hold the funds in the Service's special accounts if the full chain of movement of the digital assets cannot be traced from their origin. Conditions for returning funds held for review following the AML analysis of a transaction.

If the User does not provide the requested data and information and does not respond to the Service's requests within 6 (six) calendar months from the date the order was created, the order is deemed unfulfilled and is closed permanently without automatic resumption.

For assets whose checks have not been completed, the Service may suspend operations and restrict access to them until the necessary information is received or a final decision is made based on the AML/KYT check.

If, based on the AML/KYT check, a transaction has a high risk level and there are reasonable suspicions about the illegal origin of the funds, the Service may:

• refuse to serve the User;
• return the funds to the original requisites (where technically possible and subject to passing the check);
• transfer the information and, where there are legal grounds, the assets related to the transaction to the competent authorities;
• take other measures to prevent further use of the assets, including technical actions resulting in the loss of actual access to such assets in the cases provided for by internal AML/CTF procedures.

In these cases the assets may be restricted until the competent authorities make a decision or the situation is resolved in the prescribed manner.

Where a refund is impossible, economically unreasonable or associated with increased risks of breaching AML/CTF requirements, the Service may transfer the assets to special technical addresses (including addresses without controlled access), which results in the actual loss of access to these assets.

The User acknowledges and agrees that in these cases such assets are considered lost, are not refundable and are not compensated by the Service.

Funds are returned after a full check by the Service's security team, which may include detailed verification of the sender. A refund or processing of funds after an AML check is made minus a fee of up to 5% of the transaction amount (but not more than the equivalent of $100) to cover the cost of processing the order and arranging the refund.
A refund, if approved by the Service, will be processed within 7 (seven) calendar days from the date the User was notified of the Service's decision on their refund request.
When requesting a refund after passing the check (verification), the user must confirm the requisites for receiving the refund.

All personal and transaction data:

• is encrypted in accordance with industry best practices;
• is stored on secure servers in jurisdictions compliant with GDPR and MiCA;
• is accessible only to authorised personnel;
• is stored for at least 5 years after the end of the relationship with the client, unless otherwise required by law.