Working Hours: Mon–Fri 10:00–22:00 (UTC+3)

AML and KYC Policy

Anti-Money Laundering Policy

The AVPAY service strives to maintain effective measures to prevent and detect crimes to help law enforcement agencies combat financial crimes. The website has adopted a strict set of policies and procedures to fulfill the website's legal obligations in accordance with international legislation on combating money laundering and terrorism.

Background Information
Money laundering is the process, i.e., any action or attempt to commit an action, in which money and property (assets) obtained through criminal activity are disguised as coming from a legitimate source. In fact, money laundering is a process in which "dirty money" obtained through criminal activity is turned into "clean money," the criminal origin of which is difficult to trace. Three stages are recognized in the money laundering process.

The money laundering process consists of three stages:

  • Placement involves placing proceeds of crime into the financial system.

  • Layering involves converting the proceeds of crime into another form and creating complex layers of financial transactions to obscure the audit trail and hide the source and ownership of the proceeds.

  • Integration involves returning the laundered proceeds into the economy and creating a perception of legitimacy.

Money laundering begins with the proceeds of crime derived from a predicate offense. Predicate offenses include tax evasion, drug trafficking, bribery, fraud, forgery, murder, robbery, securities manipulation, and copyright infringement, among others. A money laundering offense may involve property or proceeds derived from illegal activities.

Terrorist financing is when you knowingly collect or provide property, such as money, directly or indirectly to terrorists. The main goal of terrorist activity is to intimidate the public or force a government to do something. Terrorists need financial support to carry out terrorist activities and achieve their goals. Many of the methods used for money laundering are also used in terrorist financing, including, but not limited to, concealing the channels of fund transmission and using third parties. They need to disguise their money so that it appears to come from another source and convert it into a form that cannot be easily traced so that it can be used.

1. Main Objectives
Customer identities are appropriately verified according to the company's risk-based approach before the website starts cooperating with them.
The website knows its customers and understands the reasons why they do business with us, both at the stage of deciding on cooperation and throughout the entire period of the business relationship.
Our employees are trained and aware of both their personal legal obligations and the legal obligations of the website.
Our employees are trained to be vigilant regarding activities where there are reasonable grounds to suspect that money laundering is taking place and to report this to the compliance officer.
A sufficient number of records are kept for the required period.
We establish, maintain, and implement appropriate procedures to achieve these objectives.

2. General Principles
Anti-Money Laundering Policy
The AVPAY service has implemented policies, procedures, and controls designed to prevent the website from being used by criminals to launder proceeds. Since the service carries out exchange operations exclusively with cash in the personal presence of the client in the office, and the processing of cryptocurrency transactions is carried out through our financial partner — the Rapira cryptocurrency exchange, these policies and procedures are adapted to this operating model.

Customer Due Diligence (CDD) and AML Control (Risk-Score model)
AVPAY has established customer due diligence procedures to identify users of its services. To prevent the legalization of illegal funds, all transactions and wallet addresses undergo mandatory verification. The service uses professional AML analyzers BitOK AML and Rapira Bot, and also relies on the internal security systems of the Rapira exchange.
A transaction is considered high-risk if the Risk Score exceeds permissible values or contains marks associated with illegal activities (Darknet Service, Mixer, Scam, Stolen Funds, etc.). Preliminary verification is carried out instantly directly in the office in the presence of the client, who has the right to familiarize themselves with its results.

In general, the CDD policy was adopted on the website to successfully accomplish the following tasks:

  • identification and verification of the applicant for business;

  • identification and verification of the beneficial owner, where applicable;

  • identification and verification when the applicant for business does not act as a principal;

  • obtaining information on the purpose and intended nature of the business relationship;

  • conducting ongoing monitoring of the business relationship;

  • establishing the source of wealth and source of funds;

  • developing a customer acceptance policy and ensuring that the applicant for business meets the requirements set out in such policy.

It is strictly prohibited on the website to have anonymous accounts or accounts under fictitious names.

Suspicious transactions
Unexplained or anomalous transactions or activities suspected of being associated with criminal activity should be immediately reported in writing to the compliance officer, who will determine whether the suspicion should be reported to law enforcement agencies.

Training
All staff must be informed of their individual and collective responsibilities and the Website's anti-money laundering policy. Staff are provided with training to enable them to understand the vulnerabilities of the Website's business, recognize, and report suspicious activities.

Record keeping
The website keeps records of those trained, the time, and the format of the training. We keep all records verifying the identity of our customers for at least 7 years after the end of the business relationship. We also keep records of any internal reports of suspicions sent to the compliance officer.

3. Our Responsibilities
International law obliges all financial service companies to:

  • Develop a program ensuring compliance with reporting, record keeping, and customer identification requirements;

  • Comply with customer identification rules and keep specific records for specific transactions;

  • Report suspicious transactions, large cash operations, and information related to terrorist property.

4. Risk-Based Approach
What is risk? Risk can be defined as the probability of an event and its consequences. Simply put, risk can be viewed as a combination of the probability that something might happen and the degree of damage or loss that may result from such an event. In the context of money laundering/terrorist financing (ML/TF), risk means:

  • At the national level: ML/TF threats and vulnerabilities that compromise the integrity of the financial system.

  • At the company level: threats and vulnerabilities that expose the company to the risk of being used for ML/TF purposes.

By default, all customers fall into the low-risk category UNLESS risk factors are present. A customer falls into the high-risk category if any of the following flags are present:

  • Politically exposed person

  • Customer about whom a suspicious transaction or terrorist financing report has been filed

  • Customer who is an identified terrorist

  • Customer for whom we cannot obtain beneficial ownership information

  • Customer from a high-risk country

Customer characteristics, product, service, delivery channel:

  • Politically exposed person, head of an international organization, and their close associates;

  • Unknown source of funds;

  • Orders for large transactions (ETF) from/to high-risk foreign jurisdictions;

  • Involvement of third parties without reasonable justification;

  • Occupation – high-risk activities (e.g., business with large cash turnovers, offshore business, business in high-risk countries, online gambling);

  • The customer's business or transaction structure appears unusually complex;

  • Inability to personally identify the customer without a valid reason.

Geography:

  • The customer resides outside the local or normal customer area;

  • The customer resides in an area where crime thrives;

  • The customer conducts offshore business, has ties to high-risk countries.

Other indicators of suspicious transactions:

  • The volume/timing/complexity of transactions do not correspond to the personal/business activity of the customer and/or the purpose of the services/account;

  • The value of deposits/transfers does not correspond to the occupation or source of funds.

5. Indicators of Suspicious Transactions or Potentially High-Risk Customers
Below are examples of some general and industry-specific indicators that may give reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing. The presence of one or more of these factors does not mean that the transaction is suspicious and should be reported to the regulatory authority, but it indicates the need for further investigation.

General indicators:

  • The customer admits or makes statements about their involvement in criminal activity;

  • The customer refuses or attempts to avoid providing required information;

  • The customer provides false documentation that appears forged or altered;

  • The customer has accounts in multiple financial institutions in the same region without apparent reasons;

  • The customer repeatedly uses the same address but frequently changes the name specified in it;

  • The customer shows unusual curiosity regarding internal controls and systems;

  • The customer makes inquiries that indicate a desire to avoid reporting requirements;

  • The customer refuses to provide identity documents;

  • The customer frequently travels to high-risk countries.

6. Data Request and Verification Procedure (KYC)
To mitigate the risks associated with money laundering and terrorist financing, we strictly do not accept or send payments to third parties (unidentified). Each customer can send and receive payments only through their own accounts.

Due to the specifics of the service's operation (offline cash exchange), if a high AML risk is detected by analyzers before the actual exchange, the order is canceled, and the customer is instantly denied the service.

However, if the transaction was sent by the customer and frozen by the algorithms (hidden trackers) of the partner exchange Rapira, the exchange will require a verification procedure (KYC) and a Source of Funds confirmation to unblock and return the funds. In this case, the customer must provide the following information:

  • A photograph of an identity document (passport or ID card);

  • A selfie (KYC check) of the customer holding the identity document and a piece of paper with the handwritten current date and the name of the "AVPAY" service;

  • Screenshots or a video recording from the personal account of the sender's wallet/exchange confirming ownership of the wallet and the origin history of the transferred funds;

  • A text or documentary explanation of the economic sense of the transaction.

Stages and processing times of the check:

  • Preliminary check: Carried out instantly before the exchange in the office using BitOK AML and Rapira Bot analyzers.

  • Notification: If the Rapira exchange freezes the transaction after the funds are sent, the customer is instantly notified by an employee, and the order is canceled.

  • Verification times (KYC/SoF): The review of the provided documents by Rapira specialists and the AVPAY security service takes from 1 to 3 business days. In complex cases requiring an extended investigation or official requests to law enforcement agencies, the review period may be extended up to 14–30 days.

Conditions, refund times, and commissions:

  • Since funds are processed through the Rapira exchange, they do not come into AVPAY's possession upon an AML block. The refund is initiated directly from the partner exchange's wallets to the sender's original address.

  • Refund time by the exchange: Up to 5 business days; in rare cases, the refund is made within 24 hours.

  • Regulated commission: According to general AML control rules, to counter malicious actors, there is a regulated right to withhold a commission for the return of high-risk (AML) funds in the amount of up to 5% of the blocked amount (but no more than the equivalent of 100 USD).

  • Actual commission: In practice, the AVPAY service and the partner exchange Rapira do not charge these penalties or their own commissions for the return. When returning funds, only the blockchain network commission necessary for the transaction is deducted from the amount.

We reserve the right to refuse to process a transaction at any stage if there are suspicions that it is related to money laundering or other criminal activity.

7. Restricted Activities and Customers
To mitigate and control the ML risk associated with a customer, the Website does not provide services and refuses to open accounts for the following customers with an unacceptable level of risk:
Individuals engaged in the following personal and/or business activities:

  • there is negative information about the customer from reliable sources (World Check, etc.);

  • customer funds were previously frozen or seized due to suspected criminal activity;

  • the customer attempts to avoid providing information or conceal their economic activity;

  • illegal trafficking in arms and ammunition;

  • unlicensed foreign exchange brokerage services;

  • organization of escort services, financial pyramids, pawnshops;

  • distribution of medicines, vitamins, tobacco, and alcohol products.

In accordance with the internal AML/CFT procedure, the website has customers of two risk categories - low and high-risk customers. Enhanced Due Diligence (EDD) must be applied to high-risk customers. A high-risk customer is one who is a politically exposed person, a member of their family, or a close associate.

8. Sanctions
The Website is prohibited from conducting transactions with individuals, companies, and countries that are on prescribed sanction lists. The Website has no AML risk appetite to establish relationships with individuals or entities listed in:

  • the sanctions lists of the US Office of Foreign Assets Control (OFAC);

  • the sanctions list of the United Nations (UN) Security Council;

  • the Consolidated List of European Union (EU) Financial Sanctions;

  • any other applicable sanctions list.

9. List of Non-Serviced Countries
The Website does not open accounts or provide services to customers from the following countries:
Afghanistan, Angola, Belarus, Bosnia and Herzegovina, Botswana, Bahamas, Cambodia, Burundi, Democratic Republic of the Congo, Central African Republic, Congo, Algeria, Ecuador, Eritrea, Ethiopia, Ghana, Guinea, Guinea-Bissau, Guyana, Haiti, Iraq, Iran, Japan, Kenya, North Korea, Lebanon, Liberia, Libya, Myanmar, Nigeria, Pakistan, Serbia, Sudan, Sri Lanka, Somalia, South Sudan, Syria, Tunisia, Trinidad and Tobago, Ukraine, Uganda, USA, Vanuatu, Venezuela, Yemen, Zimbabwe.

10. Monitoring of Suspicious Activity
The website's AML policy includes customer and beneficial owner due diligence, as well as an ongoing AML monitoring and reporting policy. At various times, the website may request information about transactions and the parties to the corresponding payment. If the customer cannot respond sufficiently or in a timely manner, the website reserves the right to reject any corresponding payments in accordance with the requirements of applicable AML laws and regulations.