AML/CTF, KYC and KYT Policy

AML/CTF, KYC and KYT policy is a set of rules and procedures that companies use to combat money laundering and terrorist financing. These policies help identify customers, verify their identity and financial data, and monitor transactions that may be associated with illegal activities.

1. Terms and Definitions

FastifyExchange (Service) — a system for providing internet services for the exchange, sale and purchase of cryptocurrency, digital and/or other electronic currencies.

User — any individual or legal entity using the services of FastifyExchange.

Cryptocurrency (digital currency) — a currency based on blockchain technology.

Electronic currency — funds held in users' accounts of electronic payment systems.

2. Goals and Objectives

The purpose of the AML/CTF, KYC and KYT policy is to prevent illegal activities in the financial sector and protect the company from potential risks. Proper application of these policies helps ensure the security of the business and clients, as well as maintain legality and order in the financial sector.

3. Enforcement Measures

3.1. AML/CTF Policy includes the following measures:

1. Customer identification and identity verification when necessary.

2. Monitoring customer transactions to identify suspicious operations.

3. If a transaction does not meet AML criteria, it is cancelled and funds are automatically returned to the client. We do not request additional data and do not conduct KYC.

3.2. KYT Policy includes the following measures:

1. Transaction tracking to identify suspicious operations.

2. In case of detection of high-risk transactions, the service simply cancels them and returns funds to the sender without additional checks.

3.3. Service actions in case of receiving a high-risk asset

1. If the AML risk level of a transaction exceeds 40%, the exchange operation is cancelled and funds are immediately returned to the sender.

2. Transactions from sanctioned services are not processed — they are instantly rejected and funds are returned to the sender.

4. Rights and Obligations of the Service:

In case of violation of AML/CTF, KYC and KYT Policy rules, the service reserves the right to:

4.1. Cancel the transaction and immediately return funds to the client without completing the exchange.

4.2. The service does not request information about the origin of funds from the client if the transaction does not meet AML criteria. The refund is carried out automatically.

4.3. All funds are returned only to the details from which the transfer was made.

4.4. The service does not delay or withhold client funds — if the transaction does not comply with AML rules, they are simply returned to the sender.

5. Risk Model and AML Analyzers

Every incoming transaction undergoes a mandatory automatic risk assessment (risk scoring) before funds are credited and paid out. The assessment is based on analyzing the origin history of the funds and any links between the address/transaction and illegal activity.

5.1. Valid AML Analyzer

For risk assessment, the service uses reports from the Bitok analytics system. Only Bitok reports are considered valid for our risk model. Reports from third-party AML services may be taken into account but are not grounds for reconsidering a decision.

Upon request, the user may be provided with a PDF report of the Bitok check performed.

5.2. Risk Scoring Scale

The result of the check is expressed as a risk percentage (risk score) from 0% to 100% and corresponds to one of the following risk levels:

• 0–24% — low risk: the transaction is considered clean, the exchange is performed as usual.
• 25–40% — medium risk: the transaction is allowed for exchange but may be subject to additional control.
• above 40% — high/critical risk: the exchange is suspended, funds are returned to the sender.

The base rejection threshold is 40%. For individual networks and payment directions, a custom (stricter) risk-score threshold may be set in accordance with the service's internal risk model.

6. Circumstances for Suspending an Exchange

An exchange may be suspended and funds returned to the sender if at least one of the following circumstances occurs:

• The transaction's risk score exceeds the established threshold (40% by default).
• The funds are linked to sanctioned persons, addresses or services.
• The funds passed through mixers, were used on darknet marketplaces, or are linked to stolen assets.
• The transaction shows signs of fraud, extortion or financing of illegal activity.
• The user refused to undergo verification (KYC) in cases where it is required to complete the operation.

Refunds are made to the sender's details minus the network fee. The service does not withhold funds and does not request KYC for automatic refunds.

7. Verification Procedure (KYC)

Verification (KYC) is required for certain exchange directions, at increased limits, and when risk-model rules are triggered. In all other cases, the exchange is performed without KYC.

7.1. List of Documents

• Personal data: country, full name (as in passport), phone number.
• Photo of the main passport page (with photo and details).
• For citizens of the Russian Federation — the passport page with registration; for others — proof of residential address.
• A selfie holding an open passport next to your face.

File requirements: clear image without glare, all data legible, JPG, PNG or WebP format, up to 10 MB in size.

7.2. Steps

• Step 1. Filling in personal data (country, full name, phone).
• Step 2. Uploading the main passport page.
• Step 3. Uploading the registration page (RF) or specifying the residential address.
• Step 4. Uploading a selfie with the document.
• Step 5. Submitting the documents for review.

7.3. Timeframes and Result

Document review usually takes up to 1 hour during business hours. After review, the application is assigned one of the statuses: "under review", "verification passed" or "verification rejected" (with the reason indicated and the option to resubmit).

All personal data is stored in encrypted form and used solely to confirm the user's identity. The service does not transfer data to third parties, except as provided by law.