AML Policy

Marketexchange.io has implemented a comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) policy to prevent its services from being exploited for illegal purposes, including money laundering, terrorism financing, or other financial crimes. This policy aligns with global regulations and local legal standards.

Purpose and Scope

The goal of this policy is to ensure that marketexchange.io operates transparently and responsibly by identifying, monitoring, and reporting any potentially unlawful activities. All transactions conducted through marketexchange.io are subject to this policy, which applies to every user and service interaction.

Verification Measures

1. Client Identification:
   • Collect full name and date of birth of the user.
   • Validate identity using official government-issued identification.
   • Confirm the user’s residential address with supporting documents such as utility bills or bank statements.
2. Document Examination:
   • Ensure submitted documentation is authentic and accurate.
   • Cross-reference user data with international watchlists and sanction databases.
3. Transaction Monitoring:
   • Conduct ongoing reviews of transactional behavior to detect anomalies.
   • Use a risk-based approach to prioritize potentially suspicious transactions.

Risk Scoring and Transaction Suspension

MarketExchange applies a comprehensive, risk-based AML scoring model to every cryptocurrency transaction using automated blockchain analytics and compliance screening tools.

Risk Level Classification

Transactions are evaluated and categorized into three risk levels:

• Low Risk (0% – 25%): Transactions proceed automatically without restriction.
• Medium Risk (26% – 40%): Standard monitoring applied. The transaction may be subject to additional automated analysis.
• High Risk (Exceeding 40% overall OR high-risk category exposure): The transaction is automatically suspended, and mandatory KYC/AML procedures are triggered.

Specific Risk-Score Thresholds & Suspension Triggers

A transaction will be immediately suspended and placed under compliance hold if ANY of the following conditions are met:

1. Overall AML Risk Score: The overall risk score of the incoming/outgoing transaction exceeds 40%.
2. Direct High-Risk Exposure: The transaction has direct or indirect exposure exceeding 0.5% to any of the following prohibited/high-risk categories:
   • Sanctions / Blacklisted Addresses;
   • Darknet Service / Dark Market;
   • Mixers / CoinJoin / Anonymizing Services;
   • Stolen Funds / Hack / Ransomware;
   • Scam / Phishing / Fraud;
   • Terrorism Financing / Human Trafficking / Child Abuse;
   • Cybercrime / Illicit Organizations.
3. External Requests: Suspension requested by liquidity providers, banking partners, or competent law enforcement/regulatory authorities.
4. Behavioral Anomalies: Multiple linked transactions attempting to split amounts (smurfing/chipping) or circumvent risk thresholds, or use of VPN/Tor/proxy servers during the session.

Handling Suspicious Activities

If a transaction or user activity raises suspicion, marketexchange.io may:

• Temporarily suspend the transaction pending further investigation.
• Request additional information from the user to verify legitimacy.
• Notify appropriate regulatory authorities when necessary.

Examples of flagged activities include:

• Use of cryptocurrency mixing services or anonymizing tools.
• Transactions involving entities or individuals subject to sanctions.
• Transfers linked to fraudulent schemes or hacking incidents.

Step-by-Step KYC Procedure & Timelines

When a transaction is flagged and suspended under our Risk Scoring Model, the customer must successfully pass the Know Your Customer (KYC) verification procedure to unfreeze or refund the assets.

Stage 1: Transaction Hold & Notification (Immediate)

• Status: Suspended.
• Action: The system automatically places the transaction on hold and notifies the User via the order page or registered email address within 15 minutes of detection.
• Instruction: The User is provided with explicit instructions and the compliance contact details to submit required verification materials.

Stage 2: Submission of Documents by User (7 Calendar Days)

• The User is required to provide the complete set of requested KYC documents within 7 calendar days from the date of initial notification.
• If the User fails to provide the required documents within 7 calendar days without reasonable justification, MarketExchange reserves the right to freeze the funds until full compliance is achieved or transfer the case to relevant legal/regulatory authorities.

Stage 3: Compliance Review & Verification (24 to 72 Hours)

• Processing Time: The Compliance Officer reviews the submitted materials within 24 to 48 hours (up to 72 hours in complex cases requiring third-party analytics or law enforcement checks) upon receiving a complete document submission.
• Additional Requests: If the submitted documents are incomplete, illegible, or require clarification, the compliance team will request supplementary information. The review period resets upon receipt of the requested additions.

Stage 4: Resolution & Final Decision

Upon completion of the compliance review, one of the following decisions will be executed:

1. Successful Verification (Exchange Completion): If documents and source of funds are fully validated, the exchange transaction is processed immediately.
2. Failed Verification / Risk Mitigation (Refund): If verification fails, or if the source of funds remains untraceable, a refund may be processed back to the original sending address, subject to a compliance processing fee of up to 5% plus applicable blockchain network/liquidity provider fees. Refunds are issued within 24 hours following the final compliance determination.
3. Asset Freeze (Regulatory Mandate): If the funds are confirmed to originate from stolen assets, sanctions violations, terrorism financing, or court/law-enforcement orders, MarketExchange is legally obligated to maintain a permanent freeze on the assets without refund pending legal resolution.

Required KYC Documents

Users undergoing enhanced due diligence must provide clear, unedited, high-resolution original copies/photos of the following documents:

1. Proof of Identity (Mandatory)

• A valid government-issued photo ID (Passport, National ID card, or Driver’s License) showing full legal name, date of birth, document number, issue date, and expiration date.
• Selfie Verification: A high-resolution selfie of the User holding the original ID document next to their face, alongside a handwritten note displaying:
  • Current Date (YYYY-MM-DD);
  • The text: “For MarketExchange Verification – Order ID #[Your Order Number]”;
  • User’s signature.

2. Proof of Source of Funds (Mandatory)

To verify the lawful origin of cryptocurrency, the User must provide:

• Transaction History & Screenshots/Video: Clear video recording or unedited full-screen screenshots showing the account/wallet from which the funds were sent (e.g., exchange withdrawal history, personal wallet transaction logs).
• Proof of Acquisition: Evidence demonstrating how the funds were legally acquired (e.g., bank statements showing crypto purchase, trading history, salary slips, proof of asset sale, or mining payout receipts).

3. Proof of Residence (Optional / Requested on Demand)

• A utility bill (gas, electricity, water), bank statement, or tax document issued within the last 3 months, clearly displaying the User’s full name and residential address.

Responsibilities of AML Officers

Designated AML officers are tasked with:

• Reviewing and monitoring daily transactions.
• Investigating and documenting suspicious activities.
• Reporting findings to relevant authorities as per legal requirements.

Data Privacy and Retention

All information collected during the KYC process is securely stored and accessible only to authorized personnel. Data retention complies with the durations specified by applicable regulations.

Additional Fees and Refunds

Transactions identified as high-risk may incur an additional fee of up to 5% to cover the costs of enhanced due diligence. Refunds for frozen assets are processed only after successful KYC verification.

User Support

For assistance with transaction inquiries, verification processes, or to preemptively check for potential blocks, users can contact marketexchange.io’s support team via live chat.

Jurisdictional Restrictions (EU/EEA)

By using the Service, the User represents and warrants that they are not a citizen, resident or tax resident of the EU/EEA, are not located in the EU/EEA, are not incorporated or established in and do not act from the EU/EEA, and do not act in the interest of or on behalf of such persons. These representations are deemed to be repeated each time the Service is used.

As part of its risk-based compliance framework, the Company applies jurisdictional restrictions and does not onboard, accept or process transactions for users located in, resident in, incorporated in, established in or acting from the EU/EEA. The Company may use IP geolocation, blockchain analytics, customer declarations, device information, payment information, KYC data and support communications to detect restricted jurisdiction exposure. Where EU/EEA exposure is detected after a transaction has been initiated, the Company may suspend the transaction, request additional information, cancel the exchange, return funds where legally permissible, or retain/block funds where required by AML/CFT, sanctions, court order, law enforcement request or internal risk controls.

The Company may, at any time and without giving reasons, refuse access, suspend or block access, refuse to execute a transaction, and terminate the relationship with the User where indicators of a connection to the EU/EEA are detected (including by IP address, geolocation, payment attributes or verification data). The use of VPNs, proxy servers, anonymisers or any other means of circumventing territorial restrictions is prohibited and constitutes an independent ground for blocking and termination.

We process IP address, device information, approximate geolocation, transaction data, wallet addresses, blockchain analytics results and customer declarations for compliance, fraud prevention, sanctions screening, AML/CFT controls and enforcement of jurisdictional restrictions.

Amendments and Updates

Marketexchange.io reserves the right to amend this policy as required to reflect changes in laws or industry standards. Users are advised to stay informed about any updates to ensure continued compliance.

This policy underscores marketexchange.io’s commitment to ethical, secure, and lawful operations, ensuring trust and transparency for all users.