AML/KYC Policy

1. Introduction

The Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML / KYC Policy”) is intended to prevent and mitigate the possible risks of bitok777.net (hereinafter simply referred to as the Service) being involved in any form of illegal activity.

2. Purpose of Internal Regulation

The Service adheres to practices and measures in the field of combating the legalization (laundering) of proceeds obtained by criminal means and the financing of terrorism (AML). The purpose of these measures is to demonstrate that bitok777.net takes seriously any attempts to use its service for illegal purposes.

3. Warning

The Service warns users against attempting to use the service for the legalization of funds obtained by criminal means, terrorist financing, fraud of any kind, as well as for the purchase of prohibited goods and services.
The Service, its administration, employees, and domain owners shall not be held liable for unlawful use of the service by third parties, actions of malicious actors, or any possible damage related to the use of the service.

4. Requirements

In order to prevent illegal transactions, the Service establishes certain requirements for all Applications created by the User:
4.1. The sender and recipient of the Payment under the Application must be the same person. The use of the Service for transfers in favor of third parties is strictly prohibited.
4.2. All contact details entered by the User in the Application, as well as any other personal data provided by the User to the Service, must be current and fully accurate.
4.3. It is strictly prohibited for the User to create Applications using anonymous proxy servers, VPNs, Tor, or any other anonymous Internet connections.

5. Verification Procedures

One of the international standards for preventing illegal activity is proper customer due diligence (hereinafter referred to as Verification). For this purpose, bitok777.net implements its own verification procedures in accordance with strict anti-money laundering standards and the “Know Your Customer” procedure.

6. AML Analyzer and Risk Assessment Model (Risk-Score)

All incoming transactions are automatically checked using an external AML analyzer — our AMLBot (an analytical service for checking addresses and transaction links). Based on the results of the analysis, each transaction is assigned a risk indicator (Risk-Score).

Risk-Score Threshold Levels:
• up to 50% — standard order processing;
• 50% and above — the order may be temporarily suspended for additional verification;
• 75% and above — KYC/SoF procedures may be required (identity and source of funds verification).
If the threshold risk level is exceeded, the exchange execution may be temporarily blocked for AML control purposes until the verification is completed.

IIf, based on the results of the verification, the exchange cannot be completed, the service issues a full refund with only the network fee deducted.
In certain cases, when an increased risk level is detected, the service may request additional information or documents for enhanced verification.

The basis for assigning an increased risk level may be the presence of ≥ 10% tags related to the following categories:

• Sanctions / High-Risk Jurisdiction
• Terrorism Financing
• Dark Market / Darknet Marketplace
• Dark Service / Illegal Service
• Ransomware / Malware
• Mixer / Mixin
• Stolen Funds / Stolen Coins
• Scam / Fraud
• Fraudulent Exchange
• Illicit Actor / Organization
• Child Abuse
• Gambling
• Protocol Privacy
• Bridge
• Decentralized Exchange (DEX)

Users may independently check their wallet address before creating an order using our preliminary AML check tool — AMLBot.

6.0. KYC/SoF Verification Process

If the acceptable risk level is exceeded as a result of an AML check, the Service may request additional verification from the user and confirmation of the source of funds. As part of the verification process, the following may be requested:

• a photo of an identity document;
• a selfie with the document;
• proof of the source of funds (screenshots, statements, and other materials).

In certain cases, the Service may request:
• A video in which the person who sent the funds, holding their passport open in their hands (where the photo and full name are clearly visible), states that they created application ID (application number) at the bitok777.net exchange service, that the funds sent are their personal funds, and that they bear full legal responsibility for this cryptocurrency; the source of funds must also be mentioned in the video;
• Record a video from the platform from which the funds were sent. In the video, we must see the transaction hash, the sender and recipient addresses, the amount with ticker, and the transaction date. The video duration must be at least 10 seconds.

6.1. In the event of blocks due to high risk or AML control procedures, the processing of the application may be temporarily suspended until the User provides the requested data (KYC/SoF) or until a decision is made on the transaction. If the User refuses to provide the requested materials or fails to provide them within the specified period, the application is terminated, and the funds are returned to the sender within 7–10 business days or, if there are legal grounds, an official escalation to the competent authorities is carried out. Indefinite retention of funds does not apply.

6.2. The Service will take steps to verify the authenticity of the documents and information provided by Users. All legal methods for double-checking identification information will be used, and the Service reserves the right to investigate cases of certain Users whose identities have been determined to be dangerous or suspicious.

6.3. The Service reserves the right to verify the User’s identity on an ongoing basis, especially when their identification information has been changed or their activity appears suspicious (unusual for that particular User). In addition, the Service reserves the right to request up-to-date documents from Users even if they have passed authenticity verification in the past.

6.4. User identification information will be collected, stored, shared, and protected strictly in accordance with the Service’s Privacy Policy and the applicable regulations.

6.5. The Service has regulatory requirements to verify the source of financial funds or cryptocurrency in order to know that the sources of funds used by Users for trading are legitimate.

6.6. If a transaction is subject to additional control under the AML/KYC policy, the Service reserves the right to conduct enhanced verification. The User is notified of the start of the verification through the contact details specified in the Application and is obliged to provide the requested information.
 

Verification Stages and Approximate Timeframes:
• automatic verification (AML analysis) — at the moment the funds are received;
• request for materials (if necessary) — after identifying an increased Risk-Score;
• review of the provided materials (KYC/SoF) — usually up to 3 (three) business days.
In cases where official escalation and interaction with competent authorities are required, the timeframes may be extended within a reasonable period, while the outcome of the transaction remains defined: return of funds to the sender or official escalation.

7. Terms and Timeframes for Refunds

If it is not possible to proceed with the exchange request based on the results of the AML check, the funds are returned to the sender within 24 hours in full, with only the network fee deducted and no additional fees applied. Including the user’s refusal to provide the data necessary for verification, the funds are returned to the sender within 7–10 business days, unless there are legal grounds for official escalation.

In the event of an AML check being triggered, the funds are returned to the user in full with only the network fee deducted. No penalty or operational fees are charged by the service.

If the client does not respond for a long time or refuses to provide additional information (which occurs extremely rarely), the funds are returned to the client’s original wallet from which the funds were received, without the need to undergo KYC verification.

8. Preliminary AML Address Check

Before sending funds, the User may perform a preliminary check of the address/transaction in the relevant section of the service (AML-checker) and decide whether to proceed with the exchange.

9. Refusal to Provide Additional Information (KYC/SoF Verification)

If, in order to complete the processing of the application or to carry out a refund, additional information is required (including KYC/SoF), and the User refuses to provide the requested data, the processing of the application is terminated.

In such a case, one of the following options may be applied:

1. The funds are returned to the sender within 24 hours in full, with only the network fee deducted and no additional fees applied.

2. In certain cases, the funds may be returned to the sender within to 10 business days.

3. Transfer of information and escalation of the case to the competent authorities if there are relevant legal grounds.

10. Responsible Officer
The person responsible for compliance with AML regulations is a person duly authorized by the bitok777.net Service, whose duty is to ensure the effective implementation of and compliance with the AML/KYC policy.

10.1. The duty of such an officer is to control all aspects of bitok777.net’s activities in combating the legalization of proceeds obtained by criminal means, including money laundering and terrorist financing, including but not limited to the following methods: collection of user identification information;
• creation and updating of internal policies and procedures for completing, reviewing, submitting, and storing all reports and records required in accordance with applicable laws and regulations;
• monitoring transactions and investigating any significant deviations from normal activity;
• implementation of a records management system for the proper storage and retrieval of documents, files, forms, and logs;
• regular updating of the risk assessment;
• providing law enforcement authorities with information required in accordance with applicable laws and regulations.

10.2. The officer responsible for AML compliance has the right to interact with law enforcement authorities involved in preventing money laundering, terrorist financing, and other illegal activities.

11. System Functions

The Service performs many tasks related to compliance, including data collection, filtering, record-keeping, investigation management, and reporting. System functions include:
• daily screening of Users against recognized “blacklists” (for example, OFAC), aggregation of transfers across multiple data points, placing users on watch and denial-of-service lists, opening cases for investigation where necessary, sending internal notifications, and filing mandatory reports where applicable;
• case and document management.

12. Behavior Analysis
The Service checks Users not only by verifying their identity, but more importantly by analyzing their transaction behavior. Therefore, the Service relies on data analysis as a tool for risk assessment and suspicion detection.

13. Risk Assessments
Bitok777.net, in accordance with international requirements, applies the practice of risk assessment to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, bitok777.net ensures that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the identified risks. If our financial monitoring or AML department identifies cases of incoming deposits (or withdrawal attempts) from the Commex platform, the funds will be blocked.

13.1. Application of Risk-Score
The risk assessment for each transaction is formed based on the AML analyzer data (Risk-Score). If the threshold values are exceeded (see clause 5.0), the Service has the right to suspend the processing of the application and request KYC/SoF materials.

Please note that we do not work with sanctioned platforms; a list of the most popular ones is provided below:

14. Conducting Customer Checks

If the administration of the bitok777.net service has reasonable suspicions that a user is attempting to use the Service for money laundering or for carrying out any other illegal transactions, the administration has the right to:
• suspend the user’s exchange transaction;
• request documents from the User that identify their identity;
• request from the User any additional information and documents in the event of suspicious transactions being carried out by them;
• ensure that reports on the suspicious nature of transactions are transmitted to the appropriate law enforcement authorities through the officer responsible for AML compliance.

15. Confidentiality

The Service guarantees the confidentiality of the client in accordance with the service’s privacy policy.
15.1. The Service and its employees undertake to maintain confidentiality with respect to any facts identified in connection with any suspicious transaction. This obligation also extends to Service users and to third parties to whom information regarding the transaction has been disclosed.
15.2. The confidentiality obligation imposed on the Service’s employees remains in force after the termination of their employment or any other contractual relationship with the Service, as well as in the event of such employees being transferred to another workplace. Disclosure of such information to state authorities, law enforcement authorities, and other entities in cases prescribed by law shall not constitute a breach of the confidentiality obligation.
15.3. The confidentiality obligation, provided that the use of disclosed information is limited to preventing the legalization of proceeds from crime and the financing of terrorism, may not be applied to the disclosure of information between financial institutions forming a consolidated group cooperating with the Service.

16. Conclusion

In view of the above, the bitok777.net service bears no legal responsibility whatsoever for its use for the purpose of legalizing funds obtained by criminal means, financing terrorism, or purchasing prohibited goods and services, but undertakes to take all possible and available actions to prevent attempts to use the Service for the purpose of legalizing funds obtained by criminal means, financing terrorism, or purchasing prohibited goods and services.
By making an exchange, the User, in accordance with the provisions of the exchange rules in force on bitok777.net, agrees to all the terms of these policies and undertakes to comply with them.