Политика AML / KYC / SoF
1. General provisions
1.1. The real AML/KYC/SoF Policy (hereinafter referred to as the "Policy") establishes principles and procedures for countering money laundering income and financing of terrorism, as well as the procedure for verifying clients and transactions on the site https://lionswapex.net/ru / (next – "Service", "LIONSWAPEX").
1.2. The Policy is an integral part of user documents. The service. The user actively agrees with Policy by means of a mandatory checkbox when creating Applications.
1.3. The Service applies a risk-based approach and has the right to suspend the execution of Applications and request supporting materials for the purposes of AML/KYC/SoF and transaction security.
1.4. The Service does not mine digital currency, does not organize mining pools, and is not an operator of the mining infrastructure.
2. Terms and definitions
2.1. AML verification – analysis of the address/TxID/transaction/chain of transactions in order to assess risks.
2.2. AML analyzer is a software product/service used for AML checks and risk-Score formation.
2.3. Risk-Score is a risk assessment (in the form of a score/percentage / category), including the classification of Low / Medium / High (or the equivalent scale of the analyzer).
2.4. AML-Hold – temporary suspension of Application execution until completion of verification and/or submission of documents.
2.5. KYC – identity verification The user.
2.6. SoF – confirmation of the Source of funds.
3. AML control tools
3.1. For AML checks The Service uses the AML analyzer(s) defined by the Administrator Services, including Rapira AML, BitOK, Analyzers from bestchange are other valid tools for analyzing blockchain transactions. In some cases, external AML reporting services may be used for the purpose of preliminary user verification or additional risk assessment.
3.2. The results of the AML analyzer are used for:
3.2.1. making a decision on the execution/suspension/refusal of the Application;
3.2.2. determining the need for KYC/SoF;
3.2.3. quality control of assets provided To the User as part of the execution of Requests (incoming/outgoing operations).
3.3. Preliminary AML verification of the digital currency address The User can be held before the details are issued as part of the Application. When identifying a high level of risk, critical tags, or other significant AML risks The Service has the right to refuse to process the Application and offer Specify a different address for the user.
4. Risk-Score model and thresholds
4.1. The Service applies a risk assessment model in which each transaction/address is assigned a Low/Medium/High risk level and/or a numerical score.
4.2. The AML-Hold threshold.
AML-Hold is applied when any of the conditions are met:
a) the risk level is High — no more than 5% in the presence of critical tags (Stolen Coins, Ransom, Child Exploitation, Terrorism Financing, Dark Market, Dark Service, Enforcement action, Scam); or
b) Medium risk level — no more than 10% in the presence of critical tags (Illegal Service, Mixer, Fraudulent Exchange, Sanctions, Gambling, etc.); or
c) Risk-Score ≥ 60 (on the analyzer scale) or another threshold set by the Administrator and published in the current edition. Politicians.
4.3. The Service has the right to apply additional AML-Hold triggers when detecting abnormal patterns, discrepancies in banking details, signs of social engineering/fraud, as well as if there are matches on the official lists.
5. KYC/SoF procedures
5.1. Depending on the level of risk The Service has the right to request one or more materials:
5.1.1. identification document (passport/ID), a selfie with the document;
5.1.2. address confirmation;
5.1.3. Confirmation of the source of funds (SoF): statement/certificate/transaction history/explanation of the origin of funds/other confirmations;
5.1.4. proof of ownership of payment details (card/account/SBP): photos, screenshots, other confirmations, and, if there are significant risks, a photo of the bank card on the background of the page. The Service and/or other materials that allow you to confirm the identity of the banking details To the user;
5.1.5. confirmation of the fact of payment/crediting: TxID, PDF receipt, statement, screenshots, video recording of the transaction history or the current account status, if necessary (including to exclude the controversial transfer).
5.2. The Service has the right to refuse service if:
5.2.1. refusal to provide materials;
5.2.2. providing deliberately false information;
5.2.3. providing materials with signs of forgery/editing.
6. Verification stages and approximate dates
6.1. Preliminary AML verification is performed before issuing the Application details and/or at other stages of processing the transaction, including checking the address of the digital currency. The User, the TxID, and other data relevant to the risk assessment.
6.2. With AML-Hold The service requests KYC/SoF materials and/or transaction confirmation.
6.3. Approximate dates:
6.3.1. Standard verification: up to 24 hours;
6.3.2. extended verification: up to 7 calendar days;
6.3.3. The deadline may be extended if the submission of materials is delayed. By the User, or if additional data verification is required.
6.4. Before submitting the requested materials, the execution of the Application may be suspended without recognizing a violation of the processing time.
7. Decisions based on the results of the audit
7.1. Based on the results of AML/KYC/SoF The service makes one of the following decisions:
a) execute the Request;
b) offer To replace the digital currency address and/or other banking details for the user, if the risk is associated with a specific address, wallet, transaction, or the transfer method used.;
c) refuse to comply and initiate a refund in accordance with Section 8 (if the refund is applicable within the framework of the settlement model and if the refund details are confirmed).
7.2. The Service has the right to request additional materials if the information originally provided is insufficient.
8. Terms and conditions of return for AML cases. Commissions
8.1. Refunds are made only to the banking details / address, the ownership of which is confirmed By the user and who passed the verification Check the validity of the refund from the point of view of AML/security.
8.2. The refund fee/deduction may not exceed the actual cost of the refund, and is additionally limited: up to 5% of the refund amount, but not more than USD 100 in equivalent at the time of the refund, plus the actual network commission.
8.3. For bona fide Users, whose KYC/SoF results have not confirmed the connection of funds with illegal sources, deductions are limited solely to the actual network commission (without additional interest).
8.4. Approximate return period after making a decision and receiving the correct details/address: up to 3 business days, unless otherwise stipulated by the operation of the bank/payment system/blockchain network or the need for additional verification of the refund details.
9. “Purity” of incoming and outgoing transactions and address policy
9.1. The Service takes reasonable measures to ensure the quality and legitimacy of the assets transferred It performs AML verification of incoming and outgoing transactions, as well as applies an internal address policy for operational wallets, acceptance addresses, consolidation addresses, and payment sources.
9.2. The Service does not allow assets from high-risk sources to be sent to the User, and it also has the right to replace the source/payment route to reduce risks.
9.3. To exclude the issue Users of high-risk assets The service uses one or more of the following approaches:
(a) accepting digital currency to operational addresses, including dynamic and/or unique addresses used for specific Applications;
(b) subsequent consolidation of incoming assets within the internal infrastructure The service;
(c) using the exchange infrastructure of proven platforms as a source of outgoing transactions For users;
(d) in some cases, the use of transit addresses previously replenished from the exchange infrastructure, subject to internal control of the origin of assets and the absence of critical AML tags at the source of funds;
(e) maintaining internal accounting and control of addresses used in operational activities, without mandatory public disclosure of the full structure of the address infrastructure.
9.4. At the request of the monitoring organizers, partners, or as part of an audit The service can provide supporting materials about the address model used and the sources of operations, including screenshots of AML analyzer reports, TxID, description of the architecture of the movement of funds and other information that does not disclose personal data. Users and who do not create unjustified risks for the security of the infrastructure The service.
9.5. The Service has the right not to publish or publicly disclose the full structure of its operational addresses, if such disclosure may create increased security risks, infrastructure blockages, restrictions from counterparties or other significant operational risks, provided that asset quality requirements are met and the necessary confirmation is provided as part of the audit.
10. Responsible for compliance AML Policies
Responsible for compliance The AML Policy Officer is a LIONSWAPEX employee whose responsibilities include ensuring compliance with the AML policy, namely:
10.1 Collection of identification information Users and its transmission to the responsible personal data processing agent;
10.2 Create and update internal policies and procedures for writing, reviewing, submitting, and storing all reports required by existing laws and regulations;
10.3 Transaction monitoring and analysis of any significant deviations from normal operations Users;
10.4 Implementation of a record management system for storing and searching documents, files, forms and logs;
10.5 Regular updating of the risk assessment.
10.6 Compliance Officer AML policy makers have the right to interact with law enforcement agencies that are engaged in preventing money laundering, terrorist financing and other illegal activities.
11. Data processing and consent recording
11.1. KYC/SoF materials are used only for the purposes of AML control, security and execution of the Application, and are processed in accordance with Privacy policy and are stored in a secure infrastructure A service with access restrictions, logging of actions, and the use of internal information security measures.
11.2. The fact of consent A user with The policy is recorded in the Service logs.
Last updated on 06/29/2026