ABCobmen Platform Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Regulations

These regulations establish the key principles for the operation of the ABCobmen cryptocurrency exchange service. (hereinafter referred to as the "Platform") in the areas of anti-money laundering (AML), counter-terrorist financing (CFT), and KYC compliance. The primary objective of this document is to reduce the risk of the service being involved in illegal financial schemes, preserve its business reputation, and maintain the trust of regulators and users. The Platform operates in accordance with FATF recommendations and the regulations of the countries where it operates.

1. Client identification and verification procedures

To access the platform"s advanced functionality and operations beyond established limits, each user must undergo a verification process. ABCobmen utilizes third-party KYC providers for data validation. The verification system is divided into two levels, determining available limits and withdrawal options.

First level (Standard)

At this stage, a basic user profile verification is performed. The following are subject to verification:

1. Validity of the email address.
2. Client’s identity (identification document).
3. Place of actual residence.

This level is relevant for standard exchange transactions and banking areas that do not carry increased risks.

Second level (Advanced)

An in-depth check is initiated when increased risks are identified or the user"s AML profile has a high status.

During this stage the following may be requested:

1. Confirm access to e-mail.
2. Identity verification.
3. Documentary confirmation of registration/residence address.
4. Documentation on the source of funds.

The decision on the need for an in-depth check is made by the security service on an individual basis, based on a risk assessment of the specific situation.

List of required documents

All provided data must be duplicated in Latin.

1. Personal identification: A current photo ID document containing the full name, date of birth, and serial number. Acceptable documents include: citizen"s passport, international passport, and driver"s license.
2. Proof of Address: A document confirming residence at the specified address for at least three months. Acceptable documents include: a certified lease agreement, bank statement, utility bills, tax notices, or other official documents.
3. Biometric verification: A photograph (selfie) of the user with the handwritten inscription “ABCobmen” and the current date on a piece of paper.

Documentary evidence of the source of funds (Source of Funds)

When undergoing extended verification, the client may be required to prove the legal origin of their capital. A sample list of documents:

1. Income from work/business: 2-NDFL certificates, contracts, declarations, individual entrepreneur reports.
2. Financial transactions: bank statements of receipts.
3. Assets and investments: purchase and sale agreements, information on dividends.
4. Other receipts: documents of gift or inheritance.

The Service reserves the right to request additional information based on the specifics of the transaction and the risk profile.

Regulatory deadlines for inspection

• Basic document verification: 1 to 24 hours.
• Enhanced Data Discovery (EDD): 24 to 72 hours.

The administration reserves the right to request document updates at any time, especially if suspicious activity is detected, even if verification has previously been successfully completed.

2. Transaction control and monitoring system (KYT)

The platform guarantees the purity of transferred assets. All crypto payments comply with international regulatory standards (OFAC, FATF) and are sent to:

• Unique one-time addresses.
• Low-risk wallets according to AML analyzers.
• Addresses of licensed exchange platforms.

Monitoring tools

ABCobmen uses a combined analysis method (automated and manual, including the AMLBot system) to scan each transaction. The check is aimed at identifying links to sanctions lists, fraudulent schemes, and darknet resources, as well as detecting the use of mixers and suspicious patterns (smurfing, abnormal volumes).

Risk scoring scale

Each operation is assigned a risk category:

• Low: Risk index up to and including 62%.
• Average: Risk index from 63% to 74% inclusive.
• High: Risk index of 75% or higher.

Transactions marked "High" are subject to manual review by an AML officer and may be blocked. Users can independently verify the address using the service bestchange.com/report/.

3. Risk management and user classification

Customer base segmentation

Depending on the level of risk, appropriate due diligence measures are applied:

1. Low risk: Standard procedure (CDD).
2. Medium risk: Enhanced monitoring with re-verification every 24 months.
3. High Risk: Enhanced Disclosure (EDD) procedure, including verification of source of funds, detailed transaction history review and annual KYC data update.

Automatic high risk criteria

The following are automatically included in the high-risk group:

• Politically exposed persons (PEP) and their close circle.
• Residents of countries from the FATF High-Risk Jurisdictions list.
• Users with an annual turnover of more than $100,000.

Actions when suspicious activity is detected

If signs of illegal transactions are detected, the Service has the right to:

• Freeze the transaction and block the account until the investigation is completed.
• Prepare a suspicious activity report (SAR/STR) and submit it to the relevant authorities (FinCEN, Rosfinmonitoring, EU FIU, etc.).
• Deny service if the client refuses to undergo verification.

Commission deductions during blocking

Funds temporarily blocked as part of an AML investigation are subject to mandatory return to the User within a period not exceeding 30 calendar days from the date of blocking, except in cases where the Platform has received an official order from authorized government agencies to seize or confiscate these assets.

Refunds are also issued in situations where the User refuses to undergo additional verification, provided there are no documents (notifications) confirming the official escalation of the case to government agencies. Permanent retention of funds is permitted only on the basis of such documents.

When refunding funds from the Platform, an administrative fee may be withheld for verification purposes. This fee is up to 5% of the blocked amount, but not exceeding the equivalent of $100. For clients whose funds are not involved in money laundering, the withholding is limited to the blockchain network fees.

Requirements for partners

ABCobmen does not cooperate with platforms from jurisdictions with weak AML controls. All counterparties undergo due diligence, are required to be licensed, and adhere to international compliance standards.

4. Internal compliance and information security

Organization of control

• Responsible person: AML officer (contact via [email protected]).
• Staff training: mandatory AML/CTF course at least once a year.
• Audit: internal quarterly, external consultants may be involved.

Data retention policy

Personal and transaction data is encrypted and stored on secure servers in GDPR- and MiCA-compliant jurisdictions. Access is restricted to authorized employees. Information is retained for at least three years after the end of the relationship with the client (unless otherwise required by law).

5. Final points

These Rules are an integral part of the User Agreement. ABCobmen administration reserves the right to update the terms unilaterally by publishing the changes on the website. Use of the platform"s services constitutes the client"s full agreement with the provisions of this AML policy.

6. Geographic restrictions and communication

Prohibited Jurisdictions

The service is not available to residents of countries and territories on the FATF, OFAC, UN, and EU sanctions lists, including:

• Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma).
• Any other territories included in the specified lists at the time of the operation.

Contacts

To report suspicious activity and contact a compliance officer, please use: [email protected]
  
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