AML/KYC

Introduction

This document provides an overview of the "Know Your Customer" and "Anti-Money Laundering" policy standards, thereby defining our methods for preventing money laundering activities when working with our users.

The purpose of the AML/KYC policy is to prevent the intentional or unintentional use of Geekchange by criminal elements for money laundering activities. The policy also prescribes making reasonable efforts to identify the true identity and beneficial owner of accounts, the source of funds, the nature of the customer’s business, the legitimacy of account transactions in relation to the customer’s business, etc., which in turn helps us reasonably manage our risks.

This document describes the AML control principles and procedures applied by our service to ensure transaction security and compliance with international standards (5AMLD/6AMLD) and anti-money laundering legislation.

We strive to protect our customers from fraud and scams in the crypto asset sector. Geekchange applies a strict approach to implementing the latest recommendations and revised guidelines of FATF, the European Parliament, and financial industry regulators in general. Our compliance policy is designed to identify funds proven to be involved in illegal activities, as well as to protect the funds of our customers who have become victims of hacks, ransomware, and malware attacks. The toolkit used to combat money laundering and its consequences consists of policy standards combined with the latest software developments aimed at tracking suspicious transactions in real time.

Our AML/KYC policy, procedures, and internal controls are designed to ensure compliance with all applicable laws and regulations and will be reviewed and updated on a regular basis to ensure that appropriate policies, procedures, and internal controls are maintained in light of changes in legislation as well as changes in our operations.

1. Customer Identification Procedure (CIP)

CIP applies to transactions that our scoring system considers suspicious. We will collect certain identifying information from each customer subject to CIP; use risk-based measures to verify the identity of each customer subject to CIP; record the customer’s identification information, verification methods, and results; and provide proper notice of CIP to customers from whom we request identifying information to verify their identity.

a. Warning

The Geekchange service warns users against attempting to use the Geekchange service for money laundering, terrorist financing, fraud of any kind, or for the purchase of prohibited goods and services.

The Geekchange service, its administration, employees, and domain owners shall not be held liable for unlawful use of the Geekchange service by third parties, malicious actors, or for any losses associated with the use of the Geekchange service.

b. Requirements

• To prevent illegal transactions, the Geekchange service establishes the following requirements for all applications created by the User:
• The sender and the recipient of the Payment under the Application must be the same person. Transfers to third parties using the Service are strictly prohibited.
• All contact information entered by the User in the Application, as well as any other personal data provided to the Service, must be current and completely accurate.
• It is strictly prohibited for the User to create Applications using anonymous proxy servers, VPNs, Tor, or any other anonymous internet connections.

c. Verification Procedures

• One of the international standards for preventing illegal activity is customer due diligence (hereinafter referred to as Verification). For this purpose, Geekchange implements its own verification procedures within the framework of strict anti-money laundering and Know Your Customer standards.
• The Geekchange service may require the User to provide documents, data, or information from reliable and independent sources (for example, a national ID card, passport, or bank statement). For such purposes, the Geekchange service reserves the right to collect User identification information to comply with the AML/KYC Policy.
• The Geekchange service will take steps to verify the authenticity of the documents and information provided by Users. All lawful methods of double-checking identifying information will be used, and the Geekchange service reserves the right to investigate certain Users whose identities have been deemed dangerous or suspicious.
• The Geekchange service reserves the right to verify the User’s identity on an ongoing basis, especially if their identification data has been changed or their activity appears suspicious (unusual for that particular User). In addition, the Geekchange service reserves the right to request up-to-date documents from Users even if they have previously passed authenticity verification.
• The collection, storage, transfer, and protection of User identification information will be carried out strictly in accordance with the Geekchange Privacy Policy and related policies.
• After confirming the User’s identity, the Geekchange service may refuse to provide services if the Geekchange service is used to carry out illegal activities.
• Users intending to use payment cards to purchase services must complete card verification in accordance with the instructions available on the Geekchange.com website.
• Geekchange has regulatory requirements to verify the source of funds or cryptocurrency to ensure that the sources of funds used by Users for trading are legitimate.

d. Responsible Officer

• The AML Compliance Officer is a person duly authorized by Geekchange security, responsible for ensuring the effective implementation and compliance with the AML/KYC policy.
• Such officer is responsible for overseeing all aspects of Geekchange’s anti-money laundering activities, including money laundering and terrorist financing, including but not limited to the following measures: collecting User identification information;
  • creating and updating internal policies and procedures for completing, reviewing, submitting, and maintaining all reports and records required under applicable laws and regulations;
  • monitoring transactions and investigating any significant deviations from normal activity;
  • implementing a document management system for proper storage and retrieval of documents, files, forms, and logs;
  • regularly updating risk assessments;
  • providing law enforcement authorities with information required under applicable laws and regulations.
• The AML Compliance Officer has the right to interact with law enforcement authorities involved in preventing money laundering, terrorist financing, and other illegal activities.

2. System Functions

• The Geekchange service performs numerous compliance-related tasks, including data collection, screening, record-keeping, investigation management, and reporting. System functions include:
• daily screening of Users against recognized “blacklists” (e.g., OFAC), aggregation of transfers across multiple data points, adding Users to watchlists and denial-of-service lists, opening investigation cases when necessary, sending internal notifications, and filing mandatory reports where applicable;
• data and document management.

3. Behavioral Analytics

The Geekchange service verifies Users not only by checking their identity but, more importantly, by analyzing their transactional behavior. Therefore, the Geekchange service relies on data analysis as a risk assessment and suspicion detection tool.

4. General Provisions and Purpose of the AML Policy

We strive for maximum transparency and security in financial transactions. Our AML policy is aimed at preventing the risk of the service being involved in illegal activities such as money laundering, terrorist financing, fraud, and other financial crimes.

By creating an application on the website, the User automatically agrees to the terms of this policy.

5. AML Analyzer Used and Risk Assessment Principles (Risk Score)

For automatic verification of cryptocurrency addresses and transactions, we use data from specialized AML analytics providers — Rapira, BitOk, GetBlock.

Based on the analyzers’ data, a final Risk Score (risk level indicator) is formed for each transaction. The system assesses the origin of funds by analyzing transaction history for links to high-risk categories such as:

• Darknet platforms (Dark Service, Dark Market)
• Mixing services (Mixer)
• Fraudulent and hacking schemes (Scam, Hacked, Stolen Coins, Phishing, Fraud)
• Sanctions lists (Sanctions) and terrorist financing
• Illegal gambling (Gambling)

6. Risk Thresholds and Service Actions

Depending on the obtained Risk Score, our algorithms or the AML Officer make the following decisions:

• Low risk level (0–30%): the transaction is processed automatically in standard mode.
• Medium risk level (30–60%): the transaction may be flagged for additional monitoring. In some cases, we may request explanations or documents from the User to clarify the source of funds.
• High risk level (over 60%): processing of the application is automatically suspended. A final decision is made after manual review by the AML Officer.

Grounds for blocking may include both an overall high Risk Score and the presence of specific «red flags» (for example, links to stolen coins or sanctioned addresses), even if the final indicator does not exceed the established threshold.

7. AML Review Stages and Timeframes

The review procedure includes the following stages:

• Automatic scoring — carried out instantly at the time of application creation.
• Detailed analysis (if risk factors are triggered) — if the system detects suspicions, the application is forwarded to the AML Officer.
• Estimated review period — from 1 to 72 hours from the moment additional information is requested from the User. In complex cases requiring interaction with merchants or liquidity providers, the period may be extended.

8. Terms and Timeframes for Refunds

If the review is successfully completed: funds are returned to the sender (or credited to the recipient) in full, minus the standard service fee.

If high risk is identified:

• If the User provides convincing proof of the lawful origin of funds (KYC, Source of Funds) within the established timeframe and receives approval from the AML Officer, the transaction will be unblocked. The Service reserves the right to charge an additional fee for enhanced due diligence — up to 5% of the blocked amount, but not more than $100 equivalent.
  
  For bona fide clients whose funds, after completing KYC and Source of Funds, are not confirmed as related to money laundering, the exchange fee remains unchanged. In case of a refund, only the network fee is withheld.
• If the User fails to provide the requested documents or the submitted data is deemed insufficient to mitigate risks, the Service reserves the right to refuse to process the transaction.
• Important: asset refunds are impossible if they have been blocked at the request of competent authorities (for example, as part of a criminal investigation) or if the sender used sanctioned platforms (for example, Garantex, Tornado Cash).

9. Recommendations for Users

To minimize the risk of blocks, we strongly recommend conducting an independent AML check of the recipient’s or sender’s address using available tools before sending funds.

The User can independently conduct a check using the following resources:

• Bestchange
• BitOk

This will allow you to assess potential risks in advance and make an informed decision.

10. Actions in Case of Refusal to Undergo Verification

If the User refuses to undergo the identification procedure (KYC) or fails to provide the requested documents or information within the established timeframe, the Service acts in accordance with applicable law and internal procedures, which implies one of the following outcomes:

• Refund of funds. The Service initiates a refund to the original address (details) within a reasonable period not exceeding 10 (ten) business days from the expiration of the deadline for providing documents. The refund amount may be reduced by the actual network (blockchain) or payment provider fees incurred by the Service as described in clause 8.
• Submission of a report to the authorized body. In cases предусмотренных by law or where there are reasonable suspicions of unlawful activity, the Service (or its infrastructure partner) has the right to file a Suspicious Activity Report (SAR) with the authorized financial monitoring authority (FIU).

11. Confidentiality

• The Geekchange service guarantees client confidentiality in accordance with the service’s Privacy Policy.
• The Geekchange service and its employees are obliged to maintain confidentiality regarding any facts identified in connection with any suspicious transaction. This obligation also applies to Service Users and third parties to whom information about the transaction has been disclosed.
• The confidentiality obligation imposed on Geekchange service employees remains in effect after termination of their employment or any other contractual relationship with the Geekchange service or transfer of such employees to another position. Disclosure of such information to governmental, law enforcement, or other organizations as permitted by law does not constitute a breach of the non-disclosure obligation.
• The confidentiality obligation, provided that the use of disclosed information is limited to preventing money laundering and terrorist financing, may not apply to disclosure of information between financial institutions forming a consolidated group cooperating with the Geekchange service.

12. Conclusion

Therefore, the Geekchange service bears no legal responsibility for its use for money laundering, terrorist financing, or the purchase of prohibited goods and services but must take all possible and available actions to prevent any attempts to use the Geekchange service for money laundering, terrorist financing, or the purchase of prohibited goods and services.

By performing an exchange, the User agrees to clause 13.5 of the section Service Rules with all the terms of these rules and undertakes to comply with them.