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AML/KYC Policy

Revision date — 10 August 2026

1. Purpose

This AML/KYC Policy (hereinafter — the "Policy") establishes the principles and internal rules applied by the Company in respect of persons using the services of the Service (hereinafter — the "User") for the purpose of complying with the requirements on countering the laundering of proceeds of crime and the financing of terrorism (AML/CFT), as well as with AML standards.

Capitalised terms used in this Policy and not defined herein shall have the meanings given to them in the User Agreement (Sections 1–3).

2. General principles

2.1. The Company acts as a Technology Intermediary (broker) assisting Users in carrying out transactions with cryptocurrency. Execution of exchange transactions is performed by Partner Licensed Exchanges in the respective jurisdictions of their operation and by Liquidity Providers.

2.2. With regard to the storage of cryptocurrency funds, the Company acts as a custodian.

2.3. AML and KYC control measures have been implemented in order to:

  • prevent the use of the Company for unlawful activity;
  • detect and suppress suspicious transactions;
  • support global compliance efforts while preserving the confidentiality of Users.

2.4. The Company carries out an AML check of all incoming transactions irrespective of their source and amount.

The check includes, inter alia:

  • analysis of addresses for sanctions exposure and other risk factors;
  • identification of incoming funds associated with mixing services (mixers) and other high-risk sources;
  • analysis of the origin of funds (taint analysis) and of the transaction history.

Where indicators of high risk or of non-compliance with the Company's requirements are identified, the exchange transaction is not created, and such funds shall under no circumstances be accepted by the Company for exchange. The funds remain in the User's Custodial Wallet within the Service; the User may withdraw them to their own independent (external) wallet, except in cases where the relevant Custodial Wallet has been blocked in accordance with the procedure provided for in clause 10.6 of the User Agreement.

This approach is aimed at minimising the risk of processing virtual assets associated with unlawful activity and at ensuring compliance with AML/CFT requirements.

3. AML/CFT Procedures

3.1. Automatic anti-money laundering checks

The Company automatically checks every exchange transaction or "send with exchange" transaction for money laundering. These checks are carried out by certified third-party AML operators (Crystal Intelligence and BitOK) under a strict non-disclosure agreement (NDA) concluded with the Company.

The system analyses the blockchain addresses involved in the transactions and assesses them against global risk indicators and blacklists (including the FATF, OFAC and similar lists).

If the AML report identifies risk indicators (for example, a high risk level, connection with sanctioned persons, use of mixing services, connection with fraudulent activity), the User shall immediately receive a notification in the interface before the transaction is completed.

3.2. On-demand anti-money laundering checks

Users may manually request an AML check for:

  • their own cryptocurrency addresses;
  • third-party wallet addresses;
  • individual transactions in supported networks.

Upon request, the system generates a risk report, which can be viewed directly in the Telegram bot @officeapp.

3.3. Reporting and notification of Users

3.3.1. Upon detection of suspicious activity, the Company may:

  • notify the User of the identified risks;
  • temporarily retain transaction data in order to comply with investigation requests (where such requests are received officially);
  • suspend a specific exchange or send transaction;
  • block the User's Custodial Wallet in accordance with the procedure provided for in clause 10.6 of the User Agreement.

3.3.2. In the event of suspension of a transaction by the Company, if the funds are held in the User's Custodial wallet and are not withheld by a Partner Exchange, a Liquidity Provider or competent state authorities, the User may request the return of the funds to the originating address (less blockchain network fees and Service fees).

After the funds have been transferred to a Partner Exchange or a Liquidity Provider, the funds cease to be under the Company's control; cancellation or reversal of the transaction by the Company is technically impossible. Further execution of the transaction is carried out in accordance with the rules and procedures of the respective Partner.

Suspension of a transaction applies exclusively to the relevant transaction or the address associated with it and does not restrict the use of the Service in respect of the User's other transactions, unless otherwise required by competent state authorities, applicable law or the compliance policies of the Partner Exchange or the Liquidity Provider. This provision does not apply to cases of blocking of a Custodial Wallet provided for in clause 10.6 of the User Agreement.

3.3.3. The Company provides User data to competent authorities solely upon an official request made in accordance with applicable law. And reserves the right to refuse to provide information to any national or foreign state bodies, law enforcement, tax and judicial authorities, or financial supervision and financial intelligence (AML/CFT) bodies where their requests do not comply with legal requirements, are unfounded or are made in breach of the established procedure.

3.4. Limitation of AML monitoring warranties

The AML check is carried out by the Company and by certified third-party operators on the basis of the principle of reasonable and sufficient efforts, using the data and technical tools available at the time of the check.

The Parties acknowledge that no AML monitoring system guarantees the detection of 100% of all possible risks related to the origin of funds, owing to the constant changes in regulatory requirements and risk indicators in various jurisdictions. The absence of risk indicators at the time of the check is not a guarantee of the absolute legality of the origin of the funds thereafter.

The Company bears no financial liability for the results of the AML check and does not warrant that it is error-free or exhaustive. The carrying out of an AML check does not release the User from the obligation to provide funds of lawful origin and does not transfer to the Company responsibility for their origin.

In the event of suspension of a transaction for the purpose of an AML check, or of delay/blocking of funds by third parties, the Company shall not compensate any financial losses caused by changes in the exchange rate of assets.

4. KYC Procedures

The Company does not carry out regular KYC verification upon registration and does not by default collect or store documents evidencing the User's identity. In exceptional cases — where funds are frozen or blocked by a Partner Exchange or a Liquidity Provider, where a Custodial Wallet is blocked in accordance with clause 10.6 of the User Agreement, or upon the demand of competent state authorities — the Company may request minimal identification information from the User solely for the purpose of resolving the relevant situation. Such data, if collected, is processed confidentially and deleted after the situation has been resolved.

5. Data processing and storage

All AML analysis results are generated and stored by the third-party operator. The Company does not retain detailed AML reports, but only risk status indicators and transaction identifiers.

The Company does not store any identity documents.

6. Training and internal control

All employees and compliance partners involved in AML/CFT processes undergo ongoing training in AML/CFT standards, blockchain forensics and risk mitigation procedures.

Internal control ensures:

  • confidential handling of compliance data;
  • compliance with non-disclosure agreements (NDAs) with third-party anti-money laundering service providers.

7. Amendments

The Company reserves the right to make changes to this AML/KYC Policy. Updates take effect immediately upon publication on the official website. Continued use of the Platform constitutes the User's consent to the updated version of the AML/KYC Policy.

8. Governing law and contacts

This Policy is governed by the laws of the Republic of Panama.

For all matters relating to the use of the Service, the User may contact the Company using the following contact details:

Legal name: SoftVision Innovations S.A.

Registered address: 10th Floor, Plaza 2000 Tower, 50th Street, Panama, Republic of Panama

Registration number (RUC): 155765203

Phone: +971 52 725 0099

Email: info@crypto-office.com

Website: https://crypto-office.com

Support service: via the Telegram bot @office_app_support_bot