AML/KYC

Policy on Anti-Money Laundering, Counter-Terrorist Financing, Sanctions Risk Management, and Fraud Prevention

Revision Date: July 2, 2026

This Policy applies to all User Orders, including transactions in the "Digital Currency → Fiat Funds" and "Fiat Funds → Digital Currency" directions. This Policy forms an integral part of the DinoExchange User Agreement.

1.1. The purpose of this Policy is to prevent the use of the Service for money laundering, terrorist financing, extremist activities, sanctions evasion, fraud, transfers made without the voluntary consent of the customer, transactions involving stolen funds, and any other unlawful or high-risk activities.

1.2. The Service applies a risk-based approach by assessing not only the User's identity, but also payment details, digital wallet addresses, transaction patterns, source of funds, country risk, sanctions risk, User behavior, and other circumstances relating to the Order.

1.3. The existence of an AML Risk Score or an individual high-risk indicator shall not, by itself, constitute a determination that the User has engaged in unlawful activity. However, it may serve as grounds for suspending an Order, conducting enhanced verification, refusing service, or issuing a refund in accordance with this Policy.

When Applied: Any Order or initial contact.

Information Requested: Full name/nickname, contact details, country, payment details, wallet address, transaction hash, IP/device information, transaction direction.

Outcome: Preliminary assessment of whether the Order can be processed.

When Applied: New Users, increased transaction amounts, inconsistent payment details, repeat Orders, or transactions involving fiat funds.

Information Requested: Identity document; selfie/photo with the document; proof of ownership of the payment card/account; proof of control of the wallet address.

Outcome: Approval for execution or a request for additional information.

When Applied: High AML risk, sanctions or country risk, PEP status, involvement of third parties, transaction splitting, unusual behavior, or a request from a bank or competent authority.

Information Requested: Documents confirming the source of funds/digital currency, bank statements, exchange screenshots, transaction history, agreements, and an explanation of the economic purpose of the transaction.

Outcome: Execution, refusal, refund, or continued suspension until the identified risk has been resolved.

When Applied: Terrorism, extremism, ransomware, stolen funds, or refusal to provide the requested documents.

Information Requested: Documents may be requested to establish the relevant circumstances and to enable a lawful refund or disclosure of information where required.

Outcome: Refusal of service, Order cancellation, refund by a legally permissible method, or compliance with the requirements of competent authorities.

3.1. Identity Documents: passport or other identification document, photo/scan of the document, selfie with the document, video identification, and confirmation of the validity of the document.

3.2. Contact Information: telephone number, email address, messenger account, country of residence, IP address, device ID, browser data, and technical identifiers necessary for fraud prevention.

3.3. Banking Information: full name of the account/card holder, masked payment card number, bank name, transfer date and amount, payment purpose, receipt/payment confirmation, bank statement, and proof that the bank account or payment card belongs to the User.

3.4. Digital Currency Information: blockchain network, sender's/recipient's wallet address, transaction hash, transaction amount, source of the digital currency, screenshots of the exchange account, deposit/withdrawal history, and proof of control over the wallet address.

3.5. Source of Funds Information: salary, business activities, sale of property, investment activities, mining, cryptocurrency trading, agreements, tax documents, receipts, bank statements, and other supporting documentation.

3.6. Additional Information: purpose of the transaction, economic rationale of the transaction, information regarding the beneficiary, representative, beneficial owner, relationships with third parties, and explanations concerning unusual transactions.

4.1. To identify high-risk transactions and wallet addresses, the Service uses the GETBlock AML Analyzer and/or other available blockchain analytics providers.

4.2. During the screening process, the Service assesses whether a wallet address or transaction is associated with high-risk sources, including but not limited to: darknet marketplaces, cryptocurrency mixers, sanctioned platforms, scam/fraud, phishing, ransomware, stolen funds, gambling/high-risk gambling, terrorist financing, extremist financing, child abuse material, illegal marketplaces, high-risk exchange services, DeFi protocols associated with unlawful activity, and other suspicious sources.

4.3. Risk Score is a cumulative risk indicator reflecting the degree of association between a wallet address or transaction and high-risk sources. The Service considers both the overall Risk Score and individual high-risk indicators, even if the overall Risk Score is formally below the established threshold.

4.4. An Order may be suspended if at least one of the following conditions is identified:

• the proportion of links to high-risk wallet addresses exceeds 15%;

• the overall Risk Score exceeds 70;

• sanctions-related, terrorist, extremist, fraudulent, or other blocking indicators are detected;

• the transaction exhibits signs of layering, obfuscation, chain hopping, transaction splitting, the use of cryptocurrency mixers, or attempts to circumvent transaction monitoring.

4.5. The Service reserves the right to modify its internal risk thresholds where necessary to reduce AML/CTF or sanctions-related risks or to comply with the requirements of banks, payment systems, liquidity providers, or competent authorities.

5.1. Fiat funds are accepted only from the User whose information matches the owner of the bank account, payment card, or electronic payment instrument, unless another procedure has been agreed upon in advance by the Service and documented accordingly.

5.2. The Service reserves the right to suspend an Order where there are indications of a transfer made without the customer's voluntary consent, social engineering, payer fraud, payment splitting, multiple transfers from different persons, discrepancies between the sender and the User, the use of nominee accounts, significant deviations from the User's normal transaction behavior, or upon request from a bank.

5.3. If a payment is received from a third party without prior approval, the Service reserves the right to request supporting documents from the User and/or the payer, refuse to execute the Order, and return the funds to the original source of the payment where technically and legally possible.

5.4. Upon receipt of a claim from a bank, payer, law enforcement authority, or payment infrastructure operator, the Service reserves the right to suspend the Order until the verification process is completed and to preserve evidence relating to the transaction.

5.5. The User shall immediately notify the Service if a payment was made by mistake, by a third party, from another person's account, as a result of fraud or deception, or if any subsequent claim arises in relation to the payment.

6.1. The Service shall not be used for transactions related to money laundering, terrorist financing, extremist activities, sanctions evasion, fraud, trafficking in narcotics, weapons, counterfeit goods, malicious software, personal data, illegal gambling, ransomware, darknet activities, cryptocurrency mixers, or any other unlawful sources or activities.

6.2. The Service does not provide services to persons subject to sanctions, persons located in prohibited or high-risk jurisdictions, persons acting on behalf of sanctioned individuals, nominee account holders, money mules ("drops"), or Users who refuse to disclose the true purpose of the transaction or the source of their funds.

6.3. The Service reserves the right to refuse service without disclosing the detailed criteria of its risk assessment model where disclosure could reduce the effectiveness of AML/KYC controls or facilitate circumvention of the verification process.

6.4. The User shall not create multiple accounts, split transactions, change payment details to circumvent limits, or use VPNs, TOR, anonymizers, or similar technologies to conceal their country, device, or actual location where such conduct creates an increased risk.

7.1. Suspension of an Order means the temporary suspension of its execution until the requested documents have been received, the internal review has been completed, a response has been obtained from a bank, payment system, or AML analytics provider, or the requirements of a competent authority have been fulfilled.

7.2. The initial verification period is generally up to five (5) business days from the date all requested documents have been received. In the event of enhanced due diligence, a request from a bank or competent authority, an international transfer, sanctions-related risk, or blockchain-related risk, the verification period may be extended for the period objectively necessary to complete the review.

7.3. If the identified risk is not confirmed and the submitted documents are sufficient, the Service shall execute the Order or offer the User an agreed recalculation or refund.

7.4. If the User refuses to provide the requested documents, provides false or misleading information, or if the identified risk cannot be eliminated, the Service reserves the right to cancel the Order, refuse further service, and issue a refund by a legally permissible method, provided that such refund is not prohibited by law or by the requirements of a competent authority.

7.5. Refunds shall generally be made to the original source of the payment. Refunds to other payment details shall be permitted only after verification and confirmation of the lawful basis for such refund. Network fees, bank fees, payment system fees, and actual expenses incurred may be deducted from the refund amount.

7.6. The Service shall retain information relating to Orders, verification procedures, correspondence, documents, transaction hashes, AML analytics results, and decisions made for the period necessary to protect the Service's rights and to comply with the requirements of applicable law, banks, payment systems, and competent authorities.

8.1. The Service reserves the right to disclose information relating to the User and the Order to banks, payment systems, AML analytics providers, legal advisers, hosting providers, telecommunications operators, governmental authorities, and law enforcement agencies in the cases provided for by applicable law, the User Agreement, and the Privacy Policy.

8.2. The Service shall not disclose to the User its internal risk assessment rules, sources of risk indicators, verification methods, or the grounds for inclusion in internal watchlists where disclosure of such information could compromise the security of the Service, banks, other Users, or third parties.

8.3. All employees, contractors, and other persons authorized to process User data are required to maintain confidentiality and to use such data solely for the purposes of processing Orders, conducting AML/KYC verification, protecting the Service's rights, and complying with applicable legal requirements.

9.1. To provide accurate information, valid documents, and explanations upon the Service's request.

9.2. To use only the User's own funds, payment instruments, and digital wallet addresses under the User's control.

9.3. Not to create circumstances that may result in claims by banks, payment systems, payment senders, digital currency recipients, law enforcement authorities, or other third parties.

9.4. To immediately notify the Service of any dispute, error, claim, bank account restriction, mistaken transfer, compromise of an account, wallet, or payment card, or any other circumstance affecting the legality or security of an Order.

9.5. To indemnify the Service for any losses and expenses arising from the provision of false or misleading information, the unlawful origin of funds, the involvement of third parties, transaction splitting, or any other violation of this Policy.

10.1. The Service reserves the right to amend this Policy by publishing a new version on the Website. The new version shall apply to Orders created after its publication unless otherwise required by applicable law, banks, payment systems, or competent authorities.

10.2. If any provision of this Policy is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

10.3. In the event of any inconsistency between this Policy and the User Agreement regarding AML/KYC matters, the stricter verification and risk management procedures shall prevail.