The Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML/KYC Policy”) is intended to prevent and reduce possible risks of involving the service https://alwaysmoney.org/ in any illegal activity.
1.1. The service https://alwaysmoney.org/ adheres to practices and measures in the field of anti-money laundering (legalization) of proceeds from crime and counter-terrorist financing (AML). The purpose of these measures is to demonstrate that AlwaysMoney takes seriously any attempts to use the Website for illegal purposes.
1.2. Risk-based AML approach. AlwaysMoney applies a risk-based approach: each Order and/or transaction may undergo automated and/or manual checks. The scope of checks and the list of requested information depend on the risk level and other triggers.
1.3. AML tools, data sources and sanctions screening. AlwaysMoney uses the following sources and tools (including, but not limited to):
1.4. Risk Score (general formation logic). The risk assessment is formed based on a combination of factors, including (but not limited to): links to sanctioned/high-risk entities, signs of unlawful activity, fraud, stolen funds; the use of obfuscation/mixing schemes and complex chains; anomalies in transaction structure (including splitting/structuring — “smurfing”); inconsistencies in the User’s data, sending/receiving addresses, geography and behavioral patterns.
1.5. Threshold values and decisions. If the risk level reaches or exceeds internal thresholds (for example, 50%), AlwaysMoney may suspend the transaction, request additional information (KYC/SoF), refuse service, or apply the refund procedure in accordance with this Policy and applicable requirements. The specified value is provided as an example and is not a guarantee of the verification outcome for any particular transaction.
2.1. The service https://alwaysmoney.org/ warns against attempts to use the Website for the legalization (laundering) of criminal proceeds, terrorist financing, fraud of any kind, as well as using the Website to purchase prohibited goods and services. The Website, its Administration, employees and domain owners shall not be liable for improper use of the service by third parties, actions of malicious actors, and possible damage associated with the use of the Website, within the limits permitted by applicable law.
3.1. In order to prevent illegal operations, the Website establishes certain requirements for all Orders created by the User:
One of the international standards for preventing illegal activity is proper customer due diligence (hereinafter referred to as Due Diligence). For this purpose, the Website implements due diligence procedures in accordance with AML standards and the Know Your Customer procedure.
4.1. Proportionality principle. AlwaysMoney applies the proportionality principle: the higher the risk, the more extensive the list of data and documents that may be requested. Requests may inсlude identity verification and/or confirmation of the source of funds (SoF).
4.2. The service https://alwaysmoney.org/ may require the User to provide reliable, independent source documents, data or information to pass verification and confirm the sources of origin of funds. The required items may inсlude:
4.3. Conditions (triggers) for requesting KYC/SoF (examples). Verification and/or SoF confirmation may be requested if: the risk level is above internal thresholds (for example, Medium/High); signs of high-risk categories or suspicious behavior are identified; signs of splitting/structuring (“smurfing”) are detected; inconsistencies in the User’s data/transaction parameters are identified; additional checks are required by an infrastructure partner (if applicable).
4.4. The service https://alwaysmoney.org/ does not support transactions with a risk of 50% or higher in the following high-risk categories: illegal service, mixing service, fraudulent, exchange, darknet marketplace, darknet service, ransom, scam, stolen coins, terrorism financing, sanctions, illicit actor/organization, high-risk jurisdiction, gambling, fraud shop, enforcement action, child exploitation. Category names may be provided in the terminology of the AML analytics provider used.
4.5. In case of блокировок due to high risk, suspicious activity or an official investigation, funds will be retained until verification is completed or the investigation is concluded. For such purposes, the Website reserves the right to collect the User’s identification information for the purposes of complying with the AML/KYC Policy.
4.6. The service https://alwaysmoney.org/ takes steps to confirm the authenticity of documents and information provided by Users. Lawful methods may be used for additional verification, and the Website reserves the right to investigate cases of Users whose activity is classified as dangerous or suspicious.
4.7. The Service reserves the right to conduct повторную/continuous verification of the User’s identity, especially if the identification information has changed or the activity appears suspicious (atypical). The Service may also request updated documents even if the User has previously passed verification.
4.8. Information about the User’s identification will be collected, stored, transferred and protected strictly in accordance with the Privacy Policy and applicable regulations.
4.9. After confirming the User’s identity, the Website may refuse to provide Services if the Website Services are used to conduct illegal activities.
4.10. The Service has requirements for checking the source of financial funds or cryptocurrency in order to ensure that the sources of funds used by Users are lawful.
4.11. The Service may not disclose the reason for blocking a transaction.
4.12. Preliminary AML pre-check before sending funds. If functionally available, AlwaysMoney may provide the ability to conduct a preliminary AML check of the address/source before sending funds. The User may: (a) undergo the pre-check and provide the result when creating the Order; or (b) refuse the pre-check, accepting the risk that the Order may be suspended and KYC/SoF documents may be requested. The pre-check is informational in nature and does not guarantee final approval, as the final decision may depend on the actual transaction and its context.
The person responsible for compliance with AML regulations is a person duly authorized by AlwaysMoney, whose duty is to ensure the effective implementation and compliance with the AML/KYC policy.
5.1. The duty of such officer is to oversee all aspects of the Website’s activities in countering the legalization of criminal proceeds, including money laundering and terrorist financing, including but not limited to:
5.2. The AML compliance officer has the right to interact with law enforcement authorities involved in preventing money laundering, terrorist financing and other illegal activities.
6.1. Infrastructure partner (CryptoCash). To process certain Orders (depending on the exchange direction, network and operational availability), AlwaysMoney may use an infrastructure partner CryptoCash to receive, process and/or make payouts. The partner may apply its own limits, compliance requirements and additional checks, which may affect the timing and the list of requested data/documents.
6.2. The service https://alwaysmoney.org/ performs many tasks related to compliance, including data collection, filtering, record keeping, investigation management and reporting. systеm functions inсlude:
7.1. The service https://alwaysmoney.org/ checks Users not only by verifying identity, but also by analyzing behavior in transactions. Therefore, the Service relies on data analysis as a risk assessment tool and for identifying suspicious activity.
8.1. The Website applies risk assessment practices to combat money laundering and terrorist financing. By applying a risk-based approach, AlwaysMoney ensures the proportionality of measures to prevent or reduce money laundering and terrorist financing with the identified risks.
9.0. If the Website Administration has reasonable suspicions that the User is attempting to use the Website Services for money laundering or for any other illegal operations, the Administration has the right to:
9.1. Standard procedure (stages) and indicative timeframes. A typical AML case may inсlude: automated screening (minutes); preliminary manual review (up to 24 hours); KYC/SoF request (if necessary) and waiting for the User’s response; review of the provided materials (usually 1–5 business days); final decision (as a rule, up to 7 business days in total, in special cases — up to 30 business days).
9.2. As a result of the investigation, the Administration makes a decision to continue the exchange or to refund the funds (less the network/payment systеm fee for sending, as well as the refund processing fee, if applied).
9.3. Proportionality principle for fees upon refund. If the User has passed verification and/or there are insufficient grounds to consider the transaction suspicious, удержания are limited to network/payment systеm fees only (without “penalty” deductions). The refund processing fee may be up to 5% of the exchange amount, but not more than 100 USD (or equivalent), and may be charged only in those AML cases during the consideration of which the exchange service incurred documented costs.
9.4. A refund or exchange, subject to its approval, will be processed by the Administration within 7 (seven) calendar days starting from the date when the User was notified of the Administration’s decision regarding their refund or exchange request.
9.5. Based on the outcome of the AML analysis of the transaction, if a decision is made to perform the exchange, the rate may be recalculated to the current one regardless of the selected tariff.
9.6. When processing a refund or exchange of funds after passing the check (verification), the User must confirm the details for receiving the refund or exchange of funds.
9.7. In cases where law enforcement authorities are interested in the User’s transaction, the investigation period may be unlimited.
10.0. The service https://alwaysmoney.org/ guarantees the User’s confidentiality in accordance with the Website’s Privacy Policy.
10.1. The Website and its employees undertake to maintain confidentiality with respect to any facts identified in connection with any suspicious transaction. This obligation also extends to the Users of the Website and to third parties to whom information on the transaction was disclosed, to the extent such obligation is provided for by applicable law and/or contractual obligations.
10.2. The obligation to ensure confidentiality remains in force after termination of employees’ work or other contractual relations with the service, as well as upon transfer of such employees to another workplace. Disclosure of information to governmental and law enforcement agencies and other entities in cases defined by law is not a breach of the confidentiality obligation.
10.3. The confidentiality limitation does not apply to the disclosure of information between financial institutions forming a consolidated group (if any), provided that the use of the disclosed information is limited to preventing the legalization of proceeds of crime and terrorist financing.
11.1. In connection with the above, the service https://alwaysmoney.org/ bears no legal liability for its use for the purpose of laundering criminal proceeds, 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 illegal purposes, within the limits permitted by applicable law.
11.2. By performing an exchange, the User agrees to all terms of this AML/KYC Policy and undertakes to comply with them in accordance with the service rules in force at https://alwaysmoney.org/.
11.3. AML/KYC contact. For AML/KYC and verification matters: info@alwaysmoney.org
