AML/CTF and KYC Policy

1. Terms and definitions
   1. AML (Anti-Money Laundering) is a process that prevents the use of financial instruments to legalize illegally obtained income. Companies that engage in financial activities must comply with AML regulations, including conducting customer compliance checks, monitoring transactions and notification of suspicious transactions.
   2. CTF (Counter-Terrorism Financing) is a process that prevents the financing of terrorist organizations. Companies must conduct customer compliance checks, transaction monitoring, and suspicious transaction notification to prevent terrorist financing.
   3. KYC (Know Your Customer) is a process used by companies to verify the identity and financial data of a customer. KYC procedures include the collection and analysis of documents, verification of their compliance, as well as the identification of the source of the client's income.
   4. Money laundering is the legitimization of the possession, use or disposal of funds or other property obtained as a result of the commission of a crime. QuietEx strictly follows the laws prohibiting us or any of our employees from knowingly engaging in or attempting to engage in any type of activity related to money laundering in one way or another.
   5. Financing of terrorism is the deliberate provision or collection of funds by any means with the intention of using these funds to commit terrorist activities.
2. Goals and objectives
   1. The aim of the AML/CTF and KYC policy is to prevent illegal activities in the financial sector and protect the company from potential risks. The correct application of these policies helps to ensure the safety of businesses and customers, as well as to maintain law and order in the financial sector.
   2. AML/CTF (Countering Money Laundering and Terrorist Financing) and KYC (Know Your Customer) are important tools that help protect our company from the risks of illegal activities and ensure the safety of our customers and their funds.
3. Enforcement measures
   1. The AML/CTF policy includes the following measures:
      • Identification of customers and verification of their identity. To do this, QuietEx can use various methods, such as requesting documents and personal data of the client, the source of origin of funds and cryptocurrencies, conducting online checks and verification of the client using its own or third-party software;
      • Monitoring customer transactions to identify suspicious transactions. If suspicious transactions are detected, QuietEx has the right to suspend the client's transaction or payment of funds;
   2. The KYC Policy includes the following measures:
      • Collecting information about customers, including their personal data, source of income, etc.;
      • Verification and confirmation of customer data through various sources;
      • Assessing the risks associated with the client and taking appropriate measures to minimize these risks;
      • Updating customer information in accordance with changes in their personal data.
   3. The KIT Policy includes the following measures:
      • Transaction tracking and identification of suspicious intentional or unintentional activity on the part of the Client;
      • Blocking the Client's funds and cryptocurrencies until the necessary information is received from him, in order to carry out a set of measures and actions in accordance with the AML/CTF, KYC and KYT policies.
      • Obtaining basic and additional information from the Client revealing the origin of digital assets and/or confirming that these assets were not obtained by criminal means;
      • The client's KYC procedure, including obtaining and verifying the authenticity of the client's personal data confirming his identity, place of registration and stay, and solvency.
      • Refund of funds, cryptocurrencies and other digital assets only to the details from which the transfer was made or refund to other details, after a full check by the Service's security service, if it was possible to confirm the legal origin of the Client's funds;
      • Withholding funds, cryptocurrencies and other digital assets of the Client until the incident is fully investigated.
   4. Actions of the service in case of receiving a high-risk asset:

      Our QuietEx service strives to ensure the safety of our customers and protect ourselves from the risks of illegal activities. The AML/CTF and KYC rules are an integral part of our security policy and we will carefully monitor their compliance.

      To determine the degree of transaction risk, the QuietEx exchange service uses its own databases, as well as specialized services Crystal Blockchain, Chain Analysis and others.

      • If the AML risk of the transaction exceeds the value of 20%, the exchange operation will be stopped for the purpose of subsequent refund of funds, cryptocurrencies or other digital assets of the client;
      • If the AML risk of the transaction exceeds the value of 90%, the exchange operation will be blocked, in order for the client to subsequently undergo the KYC procedure, as well as provide data on the origin of such assets;
      • Transactions from sub-sanctioned services will be stopped, despite the value of the degree of risk;
      • Transactions marked with victim-report (this transaction has a connection with the criminal case under investigation) will be blocked from returning funds, cryptocurrencies or other digital assets.

      We approach each AML case individually and investigate many factors, including: the date of the transaction, the percentage of different asset categories at the address, the deliberate mixing of high-risk assets with risk-free assets, etc.

   5. Sources of high-risk assets:
      • Child Exploitation – subjects related to the exploitation of children.
      • Dark Market – coins related to illegal activities.
      • Dark Service – coins related to child abuse, terrorist financing or drug trafficking.
      • Enforcement action – a legal entity is subject to legal proceedings with judicial authorities.
      • A Fraud Shop is an entity that sells various types of data, including personal information, credit card data, and stolen accounts. Fraudulent transactions usually differ from darknet markets in their behavior, such as constant replenishment of deposits and the absence of incoming transactions to customers.
      • Fraudulent Exchange – exchanges involved in exit scams, illegal behavior, or whose funds have been confiscated by government authorities.
      • Gambling - coins associated with unlicensed online games.
      • High-Risk Jurisdiction is a jurisdiction included in the list of countries that do not cooperate with FATF, has extensive malicious cryptocurrency activities or does not have a developed regulatory framework. Including countries such as Iran, Venezuela, Albania and the Democratic People's Republic of Korea, also known as North Korea.
      • Illegal Service – coins related to illegal activities.
      • An Illegal Actor/Organization is an organization or individual who is directly or indirectly involved in various forms of illegal activity. It is often associated with risky topics such as darknet markets, fraudulent transactions, extremist financing and hacking.
      • Mixer – coins passed through the mixer to make tracking difficult or impossible. Mixers are mainly used for money laundering.
      • Ransom – coins obtained by extortion or blackmail.
      • Sanctions – entities to which sanctions have been applied.
      • Scam – coins obtained by deception.
      • Special Measures – organizations or addresses identified by FinCEN as causing a high risk of money laundering. Countermeasures include record keeping, reporting requirements, and restrictions on funds transfers and account management. The scope may extend to similar authorities in other countries or jurisdictions as they are implemented.
      • Stolen Coins are coins obtained by stealing someone else's cryptocurrency.
      • Terrorism Financing – entities related to the financing of terrorism.

      If the user sends an asset that has a risk label, his funds may be frozen by the regulator indefinitely. The exchange office is not responsible for refunds from the above-mentioned dangerous sources!

4. Rights and obligations of the service

   In case of violation of the rules of AML/CTF and KYC Policy, the service reserves the right:

   1. Suspend a transaction;
   2. Request a photo or video from the user with a document confirming the user's identity (Selfie);
   3. Request a screenshot/statement from the user about the withdrawal of assets from a card, bank account, wallet, exchange or any other storage address for cryptocurrencies and other digital assets;
   4. Block the account and any transactions related to the user, transfer them to the financial control authorities and/or law enforcement agencies at the place of registration of the Service;
   5. Withhold user funds until the incident is fully investigated;
   6. To return digital assets only to the details from which the transfer was made, or switch to other details after a full check by the Service's security service, if it was possible to verify the legal origin of the user's funds;
   7. Request other materials and documents related to the exchange from the user.
   8. If the user does not provide the requested information and does not respond to the service's requests within 6 calendar months, the funds withheld will not be refunded.
5. Confidentiality
   1. The QuietEx service guarantees the client's privacy in accordance with the privacy policy of the service.
   2. The QuietEx Service and its employees undertake to maintain confidentiality with respect to any facts revealed in connection with any questionable transaction. This obligation also applies to users of the Service and to a third party to whom information about the transaction has been transferred.
   3. The obligation of confidentiality imposed on employees of the QuietEx service remains in force after the termination of their work or any other contractual relationship with the QuietEx service, as well as when such employees are transferred to another workplace. Disclosure of such information to government, law enforcement agencies and other entities in cases determined by law does not constitute a violation of the obligation of confidentiality.
   4. The obligation to ensure confidentiality, provided that the use of disclosed information is limited to preventing the legitimization of proceeds of crime and terrorist financing, cannot be applied to disclosure of information between financial institutions forming a consolidated group that cooperates with the QuietEx service.