This AML/KYC Policy describes the measures applied to reduce the risk of the service https://alwaysmoney.org/ being involved in unlawful activity, as well as the general verification procedures that may apply to user requests and transactions.
Website / AlwaysMoney means the online platform for the exchange of digital (electronic) currencies available at https://alwaysmoney.org/, including its subdomains, API, and other information resources related to the Website.
Services means the exchange operations involving digital (electronic) currencies provided through the Website.
User means any person using the Website. By using the Website, the User confirms that they are at least 18 years old, that the laws of their country do not prohibit the use of the Website, and that they do not intend to use the Services for any unlawful purpose.
Administration means the authorized personnel responsible for operating the Website and enforcing internal procedures.
Personal Data means any information relating directly or indirectly to an identified or identifiable natural person.
Request means a request submitted by the User to purchase, sell, or exchange digital (electronic) currencies through the Services.
The Service applies anti-money laundering and counter-terrorist financing measures, as well as anti-fraud and other compliance controls, in order to prevent the Website from being used for unlawful purposes.
The Service uses a risk-based approach. Each Request and/or transaction may be subject to automated and/or manual review. The scope of review, time required, and the list of requested information may vary depending on the level of risk, the nature of the transaction, and additional triggers.
The risk score is determined based on a combination of factors, including but not limited to: links to sanctioned or high-risk entities, indicators of unlawful activity, fraud, or stolen funds, the use of obfuscation schemes, mixing services, and complex transaction chains, transaction structure anomalies (including splitting/structuring, also known as “smurfing”), as well as inconsistencies in user data, sending/receiving addresses, geography, and behavioral patterns.
The final risk level (Risk Score) is determined based on a combined assessment of automated and manual criteria, including the AML analysis of the address and/or transaction, the nature and origin of the assets, any direct or indirect connections to high-risk categories, behavioral indicators, and the results of KYC and/or Source of Funds (SoF) checks where such review has been initiated.
Any direct or indirect connection to sanctioned persons, terrorist financing, stolen funds, shadow services or marketplaces, mixing services, extortion, scam activity, child exploitation, prohibited organizations, or other critically high-risk categories may constitute an independent ground for refusal of service, suspension of the Request, and/or return of funds regardless of the numerical Risk Score.
| Risk Level | Service Action | Possible Requests |
|---|---|---|
| Low Risk (0–24) | Standard processing without additional restrictions unless other triggers are present. | As a rule, no additional documents are requested. |
| Medium Risk (25–49) | Additional manual review, possible pause in processing, clarification of transaction circumstances. | Explanation of the economic purpose of the transaction, clarification of sending/receiving address details, and other reasonably necessary information. |
| High Risk (50–74) | Suspension of the Request pending completion of the review and a decision based on AML analysis. | KYC, SoF, proof of wallet/address ownership, photos, videos, statements, screenshots, and other supporting documents upon request. |
| Prohibited Risk (75–100) | Refusal to provide Services, blocking of transaction execution, and/or return of funds where permissible under the circumstances and applicable requirements. | Documents may be requested for compliance recordkeeping, verification of the lawfulness of a refund, and/or fulfillment of applicable obligations. |
The Service expressly prohibits the use of the Website for money laundering, terrorist financing, fraud, the purchase of prohibited goods or services, or any other unlawful activity.
To the fullest extent permitted by applicable law, the Website, its Administration, employees, and domain owners shall not be liable for unlawful use of the Services by third parties or for any damage resulting from such misuse.
In order to prevent unlawful transactions, the following requirements apply to Requests:
Customer due diligence is one of the internationally recognized standards for preventing unlawful activity. As part of its AML framework and “Know Your Customer” approach, the Service may apply identification, verification, and source-of-funds review procedures.
Under the principle of proportionality, the higher the identified risk, the broader the scope of data and documents that may be requested, including KYC documents and/or proof of source of funds (SoF).
The Service may request reliable and independent documents and information to verify identity, confirm control over the funds, and verify the lawful origin of assets. Depending on the circumstances, the following may be requested:
Triggers for requesting KYC/SoF may inсlude, among other things: elevated risk level, indicators of high-risk categories, suspicious behavior, signs of “smurfing,” inconsistencies in user data and transaction parameters, and additional requirements imposed by infrastructure, payment, or liquidity partners where applicable.
The Service does not support transactions with a risk level of 50% or higher in a number of high-risk categories (using the terminology of the AML provider), including but not limited to: illegal service, mixing service, fraudulent, exchange, shadow marketplace, shadow service, ransom, scam, stolen coins, terrorism financing, sanctions, illicit actor/organization, high-risk jurisdiction, gambling, fraud shop, enforcement action, child exploitation.
Where a transaction is blocked due to high risk, suspicious activity, an official investigation, or a request from competent authorities, the funds may be held until the review is completed, the investigation is closed, and/or the required information is received.
The Service may verify the authenticity of submitted documents and information using lawful means, apply additional verification measures, and conduct repeated or ongoing verification if the User’s information changes or the activity appears unusual.
Even after the User’s identity has been confirmed, the Service reserves the right to refuse to provide Services if there are indications of unlawful activity, violation of this Policy, or breach of other applicable rules.
Identification and verification data shall be processed and protected in accordance with the Privacy Policy and applicable law.
The Service may refrain from disclosing the exact reason for the blocking, suspension, or refusal of a particular transaction if such restriction is permitted by law, internal compliance procedures, or partner requirements.
The Service may offer a preliminary AML check (pre-check) before a Request is created. This check is intended to provide a preliminary assessment of whether an address, wallet, transaction, or other digital asset is acceptable under internal risk-control criteria and does not guarantee automatic approval of any subsequent Request.
When assessing risk, the Service may consider not only the documents submitted by the User and the results of formal identification, but also behavioral indicators associated with transaction activity. Data analytics may be used to identify anomalies, suspicious patterns, and other factors relevant to a compliance decision.
The Service applies risk assessment practices for anti-money laundering and counter-terrorist financing purposes. Preventive and restrictive measures are aligned with the nature and level of the identified risk.
If there are reasonable grounds to suspect that the Services are being used for money laundering, fraud, or other unlawful operations, the Administration may:
A standard AML case may inсlude automated screening (within minutes), preliminary manual review (up to 24 hours), a KYC/SoF request (where necessary), waiting for the User’s response, review of submitted materials (usually 1 to 5 business days), and a final decision. In standard cases, the overall review period usually does not exceed 7 business days, although in exceptional cases it may be extended up to 30 business days.
Following the review, the Service may decide to proceed with the exchange, refuse service, or return the funds. A return of funds may be made less network fees, payment systеm fees, provider fees, and/or a return processing fee where applicable.
If the User has successfully passed verification and/or the Service does not have sufficient grounds to classify the transaction as suspicious, deductions upon refund are generally limited to the actual network or payment systеm fees and are not intended as a penalty. A return processing fee may amount to up to 5% of the exchange amount, but no more than 100 USD (or the equivalent), and may only be charged in AML cases where actual processing costs have been incurred and can be substantiated.
A refund or completion of the exchange (if approved) is generally processed within 7 calendar days from the date the User is notified of the decision and after the payout details have been confirmed.
If the AML review results in a decision to proceed with the exchange, the exchange rate may be recalculated based on the current market rate at the time the review is completed, regardless of the previously selected tariff or rate option.
If competent authorities take interest in a transaction, the review period and any holding of funds may be extended for an indefinite period to the extent permitted by applicable law and mandatory requirements.
User confidentiality is maintained in accordance with the Privacy Policy and applicable law.
The Service and its personnel undertake to maintain confidentiality regarding facts identified in connection with suspicious, questionable, or reviewed transactions, to the extent required by law, internal procedures, and/or contractual obligations.
The duty of confidentiality survives the termination of employment, contractor, or other contractual relationships. Disclosure of information to governmental, law enforcement, regulatory, or other authorized bodies in cases предусмотренных by law shall not constitute a breach of confidentiality.
Confidentiality restrictions also do not prevent the disclosure of information within a consolidated group of financial institutions (if any), provided that such disclosure is limited to AML/CFT purposes and is lawful.
The Service shall not bear legal responsibility for attempts to use its Services for money laundering, terrorist financing, fraud, or the purchase of prohibited goods or services; however, it undertakes to apply reasonable and available measures to prevent such use to the extent permitted by applicable law.
By creating a Request, conducting an exchange, or otherwise using the Services, the User confirms acceptance of this AML/KYC Policy and agrees to comply with its provisions, as well as with any other applicable Service rules.
For AML/KYC, verification, and compliance-related inquiries, the User may contact: info@alwaysmoney.org.
