Anti-Money Laundering and Counter-Terrorist Financing Regulations (AML/CFT)

Developed based on the international standards of the Financial Action Task Force on Money Laundering (FATF) and the regulations of the countries where it operates.

With the cryptoasset ecosystem rapidly developing, financial security issues are becoming increasingly important. Coinblinker assumes full responsibility as a global financial market participant, implementing cutting-edge protocols to prevent illicit capital flows.

Operating in the cryptocurrency sector is inextricably linked to the implementation of safeguarding requirements—the integrity of financial systems. Therefore, Coinblinker has implemented a comprehensive set of control measures aimed at identifying, preventing, and mitigating attempts to exploit the platform"s services for money laundering or terrorist financing.

This document establishes the boundaries of the company"s obligations, internal control methods, and procedures for interacting with users. The document"s purpose is not only to comply with legal requirements but also to consolidate the trust of its client base, business partners, and regulatory authorities by ensuring a high degree of transparency and operational resilience.

General principles of AML/CTF activities

The Coinblinker service (hereinafter referred to as the "Service") is committed to ensuring strict compliance with the highest international standards in the field of anti-money laundering (AML) and combating the financing of terrorism (CTF). This Policy is a direct result of the recommendations of the Financial Action Task Force (FATF) and takes into account the specific legislative regimes of all jurisdictions in which the platform operates.

The primary objective of this document is to prevent the exploitation of Coinblinker"s functionality for illegal purposes. This is achieved through the creation of a multi-layered security system that ensures compliance with all applicable regulations, maintains the Service"s impeccable business reputation, and builds lasting trust among key stakeholders.

System of obligations and internal control

Coinblinker implements a comprehensive approach to AML/CTF risk management, which includes the following key elements:

• Implementation and continuous improvement of Know Your Customer (KYC) and Know Your Transaction (KYT) procedures.
• Conducting a comprehensive risk assessment associated with both specific users and individual transactions.
• Continuous monitoring of all transactions to promptly identify any abnormal or suspicious activity.
• Immediate blocking of assets and suspension of operations if signs indicating potential AML/CTF risks are detected.
• Transfer of all necessary information to authorized government agencies in strict accordance with current legislation.
• Secure storage of user personal data and full transaction history for at least five years.
• Regular training of all staff in current principles and methods of combating financial crime.
• Ensuring the legitimacy and integrity of all crypto assets transferred to users, regardless of the exchange direction or the sending method used.

All outgoing cryptocurrency transactions undergo mandatory verification to ensure compliance with international regulatory requirements, including FATF and OFAC. To minimize risks, payments are processed exclusively through:

• Unique one-time crypto addresses;
• Addresses that are considered low or medium risk by reputable AML analyzers and blockchain explorers;
• Cryptocurrency addresses belonging to licensed and regulated platforms.

Know Your Customer (KYC) procedures

To perform transactions above established thresholds, all users are required to undergo a mandatory verification process. Coinblinker partners with leading global KYC solution providers, ensuring the highest level of accuracy and security in identifying users. Based on the data collected, an informed decision is made on whether to continue providing services.

Verification structure and withdrawal limits

The service strictly adheres to the laws of its country of registration. Therefore, all users are subject to a two-step verification process.

* Level 1: Email verification. Upon successful completion of this stage, the daily withdrawal limit is increased to the equivalent of 10,000 USD (or the equivalent amount in cryptocurrencies available on the platform at the current exchange rate).

* Second level: Identity and residential address verification. Upon completion of full verification, the user is allowed to withdraw up to 100 BTC daily (or the USD equivalent).

To complete the KYC procedure, the client is required to provide the following documents:

1. a) An identity document. It must be valid and contain a photograph, full name, date of birth, and a unique identifier (series and number). Acceptable options:

• National passport;
• International passport;
• Driver"s license.

Important condition: all text data in the document must be presented in Latin transliteration.

1. b) A document confirming your residential address for the last three months. Such documents include:

• A certified copy of the lease agreement or bank statement;
• Utility bills (electricity, water, etc.);
• Tax return;
• Other official documents containing a current address and an issue date no earlier than three months ago.

Likewise, address information must be in Latin characters.

1. c) Photo (selfie): The user must provide a photo of themselves holding a piece of paper with the words "Coinblinker" written on it and the current date.

The Service conducts a thorough verification of the authenticity of all provided materials, using both automated and manual methods, including data cross-checking. If there are reasonable doubts about the client"s identity, the Service reserves the right to refuse services.

The verification process is ongoing. Even after successfully completing the initial check, the Service may request document updates, particularly if the user"s activity is deemed potentially suspicious.

Use of the platform is prohibited for residents of jurisdictions included in the blacklists of FATF, OFAC, EU, UN, as well as countries listed in the list of jurisdictions with a high AML risk (prohibited territories): Somalia, Venezuela, Afghanistan, Crimea, Iran, Myanmar (Burma), Syria, Transnistria, Yemen, Cuba, North Korea, Libya.

Processing times:

• Standard document verification: from 1 to 24 hours.
• Extended Date Determination (EDD): 24 to 72 hours.

Transaction monitoring and analysis (KYT)

Coinblinker uses a combination of automated scanners and expert analysis to evaluate each cryptocurrency transaction. It leverages solutions from recognized industry leaders (such as AMLBot and similar tools). The analysis is based on the following key parameters:

High-Risk Source Links: Check sender and recipient addresses for direct or indirect links to sanctions lists, darknet marketplaces, scams, or addresses associated with stolen assets.

Use of anonymizing tools: Identifying traces of interaction with mixers, tumblers, or protocols designed to hide the origin of funds (e.g. Tornado Cash).

Abnormal behavior patterns:

• Carrying out numerous small transfers (smurfing);
• Transactions with volumes that differ significantly from the user"s normal activity;
• Transfers to newly created wallets without transaction history;
• Transactions initiated from jurisdictions with increased AML risk.

Each transaction is assigned a risk score: Low, Medium, or High. The following assessment model is used as a guideline:

- Low Risk: The risk level does not exceed 62% on the provider"s scale.

- Medium Risk: The risk level ranges up to 70%.

- High Risk: The risk level exceeds 70%, but does not exceed 75%.

It is important to note that these assessments are subjective and reflect the position of a particular analytical provider, and do not constitute a final legal opinion on the source of funds.

Transactions classified as High Risk are automatically frozen and submitted to a dedicated AML officer for in-depth manual review. Users are advised to check their crypto addresses in advance using external AML services, such as the analytics tool on the BestChange website, to avoid delays.

Client categorization and verification levels applied

To optimize risk management processes, all users are classified into three categories depending on their inherent risk level:

- Low Risk: Standard due diligence procedure (CDD) applies.

- Medium risk: An enhanced monitoring regime is established with mandatory periodic re-verification once every two years.

- High Risk: Enhanced Due Diligence (EDD) procedures are activated, which include:

• Request and verification of the source of funds (SoF);
• Detailed analysis of the client’s entire transaction history;
• Annual update of KYC data.

The following are automatically classified as high risk:

• Politically exposed persons (PEPs), as well as their family members and close associates;
• Residents of countries included in the FATF list of high-risk jurisdictions;
• Clients whose annual turnover on the platform exceeds the equivalent of USD 100,000.

Responding to suspicious activity

If Coinblinker detects signs of possible money laundering, terrorist financing, or other illegal activity, it will immediately take the following steps:

• Pauses the suspected transaction;
• Blocks the user"s account until the internal investigation is fully completed;
• Generates and registers an internal suspicious transaction report (SAR/STR);
• If there are sufficient grounds, it transfers information to the competent authorities (including, but not limited to, Rosfinmonitoring, FinCEN, and the EU FIU).

A user"s refusal to provide the requested information or failure to undergo verification are considered sufficient grounds for termination of service.

Conditions for refund of funds within the framework of AML investigations:

If funds are blocked due to AML verification and subsequently confirmed as legitimate after KYC/SoF verification, refunds are made minus a fee. The fee is up to 5% of the blocked amount, but no more than the equivalent of 100 USD. Refunds are not possible if the assets are officially recognized as linked to illegal activity or are subject to confiscation by decision of authorized authorities. For bona fide clients who have passed verification, no additional fees are charged, and expenses are limited to network fees only.

Risk management when working with counterparties

Coinblinker has a strict policy regarding the selection of partners and service providers:

• Does not enter into business relations with platforms registered in jurisdictions where AML regulation is absent or insufficient.
• Conducts comprehensive due diligence on all potential counterparties, including crypto exchanges, payment gateways, and API providers.
• Requires all partners to have appropriate licenses and confirm their commitment to international AML/CTF standards.

Staff training and compliance audit

A designated AML officer is responsible for the coordination, implementation, and regular updating of this Policy. For all AML/CTF-related questions, please contact: [email protected] .

All Service employees undergo mandatory training on anti-money laundering and counter-terrorism financing at least once a year. To ensure the objectivity and effectiveness of the internal control system, quarterly audits are conducted, which, if necessary, may include the involvement of independent external consultants.

Privacy mode and data storage

The security and privacy of user data is an absolute priority for Coinblinker. All personal and transaction information:

• Encrypted using modern cryptographic standards that comply with industry best practices;
• Stored on physically and logically secure servers located in jurisdictions that ensure compliance with regulations such as GDPR and MiCA;
• Available only to authorized personnel who have passed the appropriate checks;
• Retained for at least five years from the date of official termination of the relationship with the client, unless otherwise required by applicable law.

Detailed terms and conditions for processing personal data are set out in a separate Privacy Policy for the website and mobile application.

Final Provisions

This AML/CTF Policy is an integral part of the Coinblinker General Terms of Service. The administration reserves the right to amend and supplement it unilaterally. All users will be promptly notified of any changes via the platform"s official website.

The use of any services provided by Coinblinker automatically signifies the user"s full acceptance and agreement with all provisions of this Policy.

Preliminary AML verification of crypto addresses

To minimize operational risks and prevent delays in processing requests, Coinblinker strongly recommends its users perform preliminary verification of cryptocurrency addresses before initiating a fund transfer. This verification identifies potential links between an address and high-risk sources, including sanctions lists, the dark web, and fraudulent resources. AML analyzers are capable of checking both native cryptocurrencies (BTC, ETH, LTC, TRON) and tokens issued on various blockchain platforms (ERC20, TRC20, BEP20, and other standards). In most cases, the identified risks are indirect and not related to intentional violations on the part of the user; however, their presence may result in the transaction being suspended for additional verification. Proactive address verification allows for automated recommendations and avoids unnecessary complications during the exchange process.