Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) Policy of the Prostovcash platform

1. Fundamental principles and objectives

Prostovcash platform conducts its activities in strict compliance with international standards in the fight against financial crime. This document has been compiled taking into account the laws of the countries in which the Service operates and the recommendations of the Financial Action Task Force (FATF).

Key objectives of the Policy:

• Preventing the use of the site for illegal operations.
• Guaranteed compliance with regulatory requirements.
• Maintaining the business reputation of Prostovcash.
• Strengthening trust among the customer base and regulatory authorities.

2. Protection and storage of information

User data privacy is a priority for Prostovcash.

• Encryption: Information is protected in accordance with current industry standards.
• Server Location: Data is hosted on secure facilities in jurisdictions that comply with MiCA and GDPR regulations.
• Access: Only authorized personnel are allowed to work with information.
• Retention period: Personal and transaction data is retained for at least 5 years after the end of the relationship with the client.

3. User Identification (KYC)

To pass verification, the client must provide scans or photographs of the following documents (transliteration into Latin is required):

Identity card:

1. Passport (domestic or international).
2. Identity card (ID card).
3. driver"s license.

Proof of residence (document valid for up to 3 months):

1. Bank statement or lease agreement.
2. Receipts for utility services.
3. Tax return.
4. Other official documents containing the registration address.

Additional requirement:

• A user photo (selfie) holding a piece of paper with the name "Prostovcash", a personal signature, and the current date written on it by hand.

Keeping your funds safe: Verification of source (SoF)

To maintain the security of the ecosystem, the service sometimes requests additional information about the origin of funds as part of AML monitoring. This helps us ensure security for all platform participants.

Examples of suitable documents:

• Screenshots of wallet/transaction data;
• bank statements or stock exchange transaction history;
• certificate of income or other confirmation of the legality of assets.

Sanction restrictions:

Providing services to clients from jurisdictions subject to UN, EU, OFAC, or FATF sanctions is prohibited. These prohibited regions include: Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma), and any other territories included in the sanctions list at the time of the transaction.

Verification deadlines:

• Standard procedure: 1 to 24 hours.
• Extended Duration (EDD): 24 to 72 hours.
• Note: The service reserves the right to request re-verification if there are any suspicions.

4. Transaction monitoring (KYT) and risk assessment

The service uses data from specialized blockchain analytics providers, including market-leading solutions such as Crystal, BitOK, and GetBlock.

Factors that increase the risk:

1. Connection of addresses to darknet markets, fraudulent schemes, or sanctions lists.
2. Use of anonymization tools (mixers, including Tornado Cash).
3. Suspicious patterns (smurfing, transactions from disadvantaged regions).

Risk Score:

Important: Threshold values may vary depending on the software. A detailed description of the Risk-Score model is available at: https://www.bestchange.ru/wiki/detailed_aml_recommendations.pdf#page=72

Transactions marked as High Risk may be blocked automatically. Users can check them in advance on the service"s AML page or use the tool: https://www.bestchange.ru/report/.

5. Client categorization and risk management

The client base is segmented into three groups depending on the level of risk:

1. Low Risk: Passes standard check (CDD).
2. Medium risk: Subject to enhanced monitoring, re-testing required every 2 years.
3. High Risk: Enhanced Due Diligence (EDD) is applied. This includes confirmation of the origin of funds, transaction history analysis, and annual KYC updates. This includes PEPs (politically exposed persons) and their associates, as well as residents of countries on the FATF High-Risk list.

In case of refusal of verification:

• Funds may be frozen for up to 7-10 business days.
• After this period has expired, the issue may be referred to the competent authorities (financial intelligence, law enforcement agencies).

6. Reaction to suspicious activity

If signs of illegal transactions are detected, the Prostovcash administration takes the following actions:

1. The operation is suspended immediately.
2. The account is blocked until the investigation is completed.
3. An internal report (SAR/STR) is generated.
4. If necessary, notifications are sent to regulators (Rosfinmonitoring, FinCEN, EU FIU).

Financial terms for refund:

• The refund fee for AML cases is up to 5% of the amount, but does not exceed $100.
• For bona fide users whose funds are not involved in money laundering, the commission is limited to network fees.
• Refunds will not be made if funds are deemed criminal and subject to confiscation at the request of regulators.

7. Internal control and partner network

Requirements for counterparties:

• Cooperation with platforms from jurisdictions with weak AML regulations is prohibited.
• Mandatory due diligence procedure for partners.
• Partners must be licensed and comply with international standards.

Training and audit:

• AML Officer: [email protected].
• Annual professional development for employees in the field of AML/CTF.
• Conducting internal audits quarterly (if necessary, external experts are involved).

8. Final Provisions

This Policy constitutes an integral part of the Prostovcash platform User Agreement. The service reserves the right to make changes unilaterally by notifying users through the official website. Using the services constitutes full acceptance of the terms of this Policy.

All payments comply with the standards of international regulators (OFAC, FATF) and are carried out through:

1. Licensed platforms.
2. Low-risk addresses (confirmed by AML analyzers).
3. Unique one-time crypto addresses.