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    Copyright © 2022-2026 nordchange

    AML policy of Nordchange service

    Nordchange platform (hereinafter referred to as the "Service") adheres to strict principles of financial transparency and information security in its operations. We have implemented a comprehensive system of measures aimed at preventing the use of the platform"s infrastructure for money laundering (AML) and counter-terrorist financing (CTF). In developing and implementing these measures, we are guided by the international standards of the Financial Action Task Force (FATF), as well as the regulatory requirements of the jurisdictions in which the Service operates.

    The primary objective of this policy is to minimize the likelihood of abuse of the platform for illegal purposes, strictly comply with regulatory obligations, maintain the operator"s business reputation, and strengthen the trust of users, regulatory authorities, and business partners.

    1. Service Obligations

    1.1 The Nordchange service guarantees the fulfillment of the following key obligations in the field of financial monitoring:

    - development, implementation and regular updating of customer identification procedures (Know Your Customer, KYC) and transaction activity analysis (Know Your Transaction, KYT);

    - conducting a comprehensive assessment of the risks associated with the client profile and the nature of their financial transactions;

    - continuous monitoring of all transfers in real time to identify indicators of suspicious or abnormal activity;

    - immediate blocking or suspension of operations upon detection of signs indicating possible violations of the AML/CTF regime;

    - transfer of relevant information to authorized government agencies in cases expressly provided for by current legislation;

    - ensuring confidential storage of personal data and transaction information for a period of at least five years from the end of the relationship with the client;

    - organizing regular training programs for employees on compliance with anti-money laundering and counter-terrorism financing requirements;

    - verification of the legal origin of all crypto assets entering or leaving the platform, regardless of the direction of the exchange transaction or the chosen transfer method.

    1.2 All outgoing cryptocurrency transactions comply with international AML standards, including FATF recommendations and sanctions restrictions of the U.S. Treasury Department"s Office of Foreign Assets Control (OFAC). Funds are transferred exclusively through the following channels:

    - unique one-time addresses generated for each individual operation;

    - addresses that have passed multi-stage verification and are classified as low-risk by leading AML analysis systems and blockchain explorers;

    - wallets belonging to licensed and government-regulated cryptocurrency platforms.

    1.3 Customer verification procedures (KYC)

    Extended access to the platform"s features is granted to users only after successful identification, which is a mandatory requirement for compliance with regulatory requirements and maintaining security standards. To meet KYC requirements, Nordchange utilizes solutions from trusted external verification providers with whom it has signed appropriate confidentiality and personal data processing agreements. Based on the results obtained, a decision is made on whether to grant access to the platform"s extended functionality.

    2. KYC verification levels

    2.1 The service strictly adheres to the laws of its country of registration. To gain full access to operations, you must complete a two-step verification process.

    Verification procedure

    Access to advanced platform features beyond basic quotas is granted only after successful client identification. Nordchange utilizes specialized solutions from external KYC operators to validate data. The authentication process is structured across two levels, defining withdrawal limits:

    Level 1: Standard Identification

    A basic verification framework applied to transactions with a low risk profile.

    Verifiable parameters:

    • email address relevance;
    • identity card (state document);
    • confirmation of registration address or actual residence.

    This level is sufficient for working with individual banking areas and conducting transactions that are not classified as high-risk.

    Level 2: Enhanced Data Discovery (EDD)

    Activated when high-risk indicators are detected or the client is assigned the corresponding AML status.

    Extended list of requirements:

    • re-validation of contact information (e-mail);
    • in-depth identification of personality;
    • documentary proof of residential address;
    • justification of the legitimacy of the origin of funds (clause 2.2.4).

    The decision on the need to move to an advanced level is made by the Service on an individual basis based on the results of a risk-based analysis of the specific situation.

    2.2 To complete the KYC procedure, you must provide the following documents and materials:

    2.2.1 An identity document containing the holder"s photograph, full name, date of birth, and unique identification number (series and number). Acceptable options are:

    - internal passport of a citizen of the state;

    - foreign passport;

    - driver"s license.

    All text elements of the document must be presented in Latin transliteration.

    2.2.2 A document confirming the registered or actual residential address, issued no earlier than three months prior to the application submission date. The following are accepted as supporting documents:

    - bank statement or officially certified lease agreement;

    - utility bills (for electricity, water supply and other utilities);

    - tax return;

    - other official government documents indicating the current address.

    Text information in the document must also be presented in Latin letters.

    2.2.3 A photo of the user (selfie) taken with a sheet of white paper on which the name of the platform "NORDCHANGE" is clearly written and the current calendar date is indicated.

    2.2.4 Requirements for documentary justification of the origin of assets (SoF)

    During in-depth verification, the platform reserves the right to request proof of the legitimacy of capital sources. The list of accepted documents is public and covers the following categories:

    • Income from employment and commercial activities: employment contracts, tax returns, income statements, financial statements of business entities.
    • Transactions using bank details: statements confirming the fact and source of funds transfer.
    • Asset management income: property purchase and sale agreements, dividend distribution reports, investment declarations.
    • Gratuitous receipts: certificates of inheritance, notarized gift agreements.

    The specific list of requested documents is compiled by the compliance department individually, based on the results of risk scoring for each client.

    2.3 The service conducts a multi-level verification of the authenticity of submitted documents, including data comparison with open sources and analysis of the visual characteristics of the materials. If there are reasonable doubts about the veracity of the information, access to advanced functionality may be temporarily restricted or completely denied.

    2.4 Re-verification of a client may be initiated by the Service administration at any time, especially upon detection of activity that is atypical for the user"s profile or transactions characterized by increased risk, even if the client has previously successfully passed a full verification.

    3. Jurisdictional restrictions

    3.1 Use of the Service is prohibited for individuals and legal entities located in territories included in the sanctions lists of the FATF, OFAC, the European Union, and the United Nations, as well as in countries officially recognized as high-risk AML zones. Such jurisdictions include: Afghanistan, Iran, the Democratic People"s Republic of Korea, the Syrian Arab Republic, Yemen, Libya, Somalia, Cuba, the Republic of Crimea, the Transnistrian Moldavian Republic, Venezuela, and Myanmar (Burma).

    3.2 The processing time for verification applications is:

    - standard verification: from 1 to 24 hours from the moment of receiving a complete package of documents;

    - Extended Date Discovery (EDD): 24 to 72 hours in cases requiring additional analysis or a request for clarification.

    4. Transaction monitoring (KYT)

    4.1 Nordchange uses a combined approach to analyzing cryptocurrency transactions, combining automated blockchain scanning tools with expert manual assessment. This work utilizes solutions from leading international AML analytics providers. The analysis process includes:

    - checking the sender and recipient addresses for direct or indirect links to sanctioned databases or high-risk clusters (darknet marketplaces, fraudulent schemes, stolen funds and other sources);

    - identifying instances of the use of mixers, tumblers or anonymizing protocols, including solutions such as Tornado Cash;

    - detection of abnormal behavior patterns:

    multiple microtransactions (smurfing technique);

    operations with volumes significantly exceeding the historical profile of user activity;

    transfers to wallets with no transaction history or minimal activity;

    transactions initiated from jurisdictions with relaxed AML/CFT regulations.

    4.2 Each operation is assigned a quantitative risk assessment, classified into three categories:

    - low risk (Low Risk) - the total indicator does not exceed 62%;

    - average risk (Medium Risk) - the result is in the range from 63% to 73%;

    - high risk (High Risk) - the threshold value reaches 74% and higher.

    4.3 It is important to note that these assessments reflect the algorithmic interpretation applied by a particular analytics provider and do not always conclusively indicate the illicit origin of the assets or the illegal activity of the sender.

    4.4 Transactions classified as High Risk may be automatically suspended by the system and referred to the AML Officer for detailed analysis.

    4.5 Users are strongly advised to conduct a preliminary AML check of the recipient"s cryptocurrency address before initiating a funds transfer. This feature is available on the specialized monitoring service BestChange at https://www.bestchange.com/report/. This tool analyzes both native cryptocurrency addresses (BTC, ETH, LTC, TRON) and ERC20, TRC20, and BEP20 tokens, providing a risk assessment and recommendations based on the scan results.

    5. Client categorization and verification levels

    5.1 Depending on the level of risk identified, clients are divided into three categories with corresponding control procedures:

    - low risk: standard verification (CDD) is applied without additional requirements;

    - medium risk: enhanced monitoring of transactions and re-verification of personal data every two years are implemented;

    - high risk: Enhanced due diligence procedures (EDD) are implemented, including:

    • request for documentary confirmation of the source of funds (clause 2.2.4);
    • detailed analysis of transaction history for the previous period;
    • annual updating of KYC data and provision of additional information on the nature of financial activities.

    5.2 The following categories of clients are automatically classified as high risk:

    - persons holding politically exposed positions (PEPs), as well as members of their families and close affiliates;

    - residents of countries included in the list of jurisdictions with insufficient anti-money laundering measures (FATF High-Risk Jurisdictions);

    - clients whose total annual turnover exceeds the equivalent of US$100,000.

    6. Processing suspicious transactions

    6.1 If signs of money laundering, terrorist financing or other illegal activity are detected, the Nordchange Service:

    - immediately suspends the transaction until the internal investigation is completed;

    - blocks the client’s account for the duration of the analysis;

    - generates and registers a suspicious transaction report (Suspicious Activity Report / Suspicious Transaction Report);

    - if there are sufficient grounds, notifies the competent financial monitoring authorities (including Rosfinmonitoring, FinCEN, financial intelligence units of the European Union countries and other authorized structures).

    6.2 A client’s refusal to provide the requested information or failure to undergo verification are considered independent grounds for termination of service and complete blocking of the account.

    6.3 The User is guaranteed access to their funds within one month following their temporary suspension for AML security reasons. The Platform is not entitled to withhold funds indefinitely in the absence of an official seizure order issued by government authorities. This rule applies even if the User fails to respond to a request for additional verification.

    6.4 Upon the return of funds, a fee may be deducted to cover administrative verification costs (capped at 5% of the amount or $100, whichever is lower). However, if the investigation reveals no evidence of money laundering, the financial burden on the client is reduced to the standard fees applicable to the blockchain network.

    7. Interaction with third parties

    7.1 Nordchange Platform:

    - does not cooperate with platforms registered in jurisdictions with insufficient levels of regulation in the area of AML/CFT;

    - conducts a comprehensive due diligence check of all potential counterparties (cryptocurrency exchanges, payment providers, API partners);

    - requires business partners to have valid licenses and documented evidence of compliance with international anti-money laundering standards.

    8. Training and internal control

    8.1 Responsibility for the development, implementation and ongoing updating of this policy is assigned to the designated authorized employee - the responsible AML officer.

    8.1.1 Contact for prompt interaction on AML/CTF compliance issues: support@nordchange.net.

    8.2 All Service employees undergo mandatory training on anti-money laundering and counter-terrorism financing at least once a year. Internal audits of the control system"s effectiveness are conducted quarterly; if necessary, external auditors and consultants are engaged to conduct an independent assessment.

    9. Data storage and protection

    9.1 Customer personal data and transaction information:

    - are encrypted in accordance with industry information security standards;

    - stored on secure server facilities located in jurisdictions that comply with the General Data Protection Regulation (GDPR) and the Market for Cryptocurrency Asset Regulation (MiCA);

    - available only to authorized personnel who have passed additional verification;

    - are retained for a period of at least five years after the termination of the relationship with the client (unless otherwise provided by applicable law).

    9.2 The provisions of the privacy policy apply to all components of the platform ecosystem, including the website and mobile applications.

    10. AML/KYC rules and transaction control

    10.1 The Nordchange Service Administration reserves the right to initiate additional checks on user activity depending on the nature, volume, and frequency of transactions, requesting additional information and documents if necessary. Completed transactions are subject to retrospective analysis to identify potential economic violations and ensure comprehensive platform security. If an incident is detected, the client is notified of the investigation; if the violation is minor (e.g., a technical error), the user is given a reasonable period to correct the deficiencies. In the event of refusal to cooperate or confirmation of serious violations, the account may be frozen or completely blocked.

    10.2 Registration on the Nordchange platform signifies the user"s unconditional acceptance of the Service"s security policy and AML/KYC requirements, which include multi-level personal identification and the ability to conduct both scheduled and unscheduled checks of personal data and financial activity. These measures are intended to reliably protect the ecosystem from illegal use, thereby creating conditions for the stable and secure operation of the platform in the interests of all digital asset market participants.