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AML/KYC Policy

Revision date — 23.09.2026

1. Purpose

This AML/KYC Policy (hereinafter, the "Policy") sets out 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 for countering the laundering of proceeds of crime and the financing of terrorism (AML/CFT), as well as AML standards.

Terms used in this Policy with a capital letter and not defined directly herein have the meanings set out in the User Agreement (Sections 1–3).

2. General Principles

2.1. The Company acts as a Technology Intermediary assisting Users in carrying out cryptocurrency operations. Exchange operations are executed by licensed Partner Exchanges in the relevant jurisdictions of their activities and by Liquidity Providers.

This Policy governs AML/KYC procedures exclusively in respect of operations with digital assets within the Platform. Compliance control, risk identification and transaction screening procedures related to the use of the Card Service (Office Card module) are governed by the rules of the Card Service itself by Financial Services LTD (England and Wales), the laws applicable to it and the rules of independent Issuing Partners.

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 for:

  • preventing the use of the Company for illegal activities;
  • identifying and suppressing suspicious transactions;
  • supporting global compliance efforts while maintaining the confidentiality of Users.

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

The check includes, among other things:

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

Where indications of high risk or non-compliance with the Company's requirements are identified, the exchange operation is not created, and such funds are under no circumstances 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 Independent (External) Wallet, except where a notification has been received from a Partner Exchange / Liquidity Provider in respect of the wallet that the address is on a blacklist, an order of a public authority has been received, or a direct connection with sanctions lists has been identified. In these exceptional cases, the withdrawal of funds is not permitted, and the Company may block the Custodial Wallet in the manner set out in clause 10.6 of the User Agreement.

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

2.5. This Policy applies equally to operations of transferring digital assets from the User's Custodial Wallet for the purpose of topping up card products within the Office Card module, which operates on the Platform under the management of Financial Services LTD (England and Wales). Funds directed to top up such card products undergo the same AML screening procedures as are provided for by this Policy for outgoing operations.

3. AML/CFT Procedures

3.1. Automatic Anti-Money Laundering Checks

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

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

If indications of risk are identified in the anti-money laundering report (for example, a high level of risk, a connection with sanctioned persons, the use of mixing services, a connection with fraudulent activity), the Company notifies the User in the interface.

3.2. On-Demand Anti-Money Laundering Checks

Users may manually request an AML check for:

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

Upon request, the system generates a risk report, which can be viewed directly in the Telegram Mini App (@officeapp) and the Telegram bot (@office_app_bot).

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 to fulfil investigation requests (if they have been received officially);
  • suspend a specific exchange or sending operation;
  • block the User's Custodial Wallet in the manner set out in clause 10.6 of the User Agreement.

3.3.2. In the event of Suspension of an operation by the Company, if the funds are held in the User's Custodial Wallet and are not withheld by a Partner Exchange, Liquidity Provider or competent public authorities, the User may request the return of the funds to their Independent (External) Wallet (less blockchain network fees and Service fees).

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

Suspension of an operation applies exclusively to the relevant operation or the address associated with it and does not restrict the use of the Service in respect of the User's other operations, unless otherwise provided by the requirements of competent public authorities, applicable law or the compliance policies of the Partner Exchange or 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 Users' data to public authorities, including financial supervisory authorities and financial intelligence authorities, in the manner and on the grounds set out in clause 4.4 of the Privacy Policy.

3.4. Limitation of AML Monitoring Guarantees

The AML check is carried out by the Company and 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 User acknowledges that no AML monitoring system guarantees the detection of 100% of all possible risks associated with the origin of funds, due to 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 lawfulness of the origin of the funds in the future.

The Company shall not be financially liable for the results of the AML check and does not guarantee its accuracy or exhaustiveness. The performance 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 an operation for the purpose of an AML check or delay/blocking of funds by third parties, the Company does not compensate possible financial losses caused by changes in the exchange rate of assets.

4. KYC Procedures

The Company provides software and technical services and is not a licensed bank, financial institution or credit and financial organisation. Accordingly, the Company does not carry out regular KYC verification upon registration and by default does not collect or store the User's identity documents. In exceptional cases — upon a Freeze or blocking of funds by a Partner Exchange or Liquidity Provider, upon Blocking of a Custodial Wallet in accordance with clause 10.6 of the User Agreement, and at the request of competent public 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 stored in the manner set out in Section 5 of the Privacy Policy.

Identity verification (KYC), document verification and payment card holder verification procedures are carried out exclusively on the side of independent Issuing Partners in accordance with their own regulatory requirements. The Company does not verify documents, does not request Personal Data and does not store copies of Users' identity documents for the issuance or servicing of cards in the Card Service.

5. Data Processing and Storage

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

The Company does not collect or store identity documents as part of the regular functioning of the Service. If such documents are provided by the User upon the occurrence of exceptional events (clause 4 of this Policy), the information is stored in an encrypted archive for the period set out in Section 5 of the Privacy Policy.

6. Training and Internal Control

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

Internal control ensures:

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

7. Amendments

The Company may make amendments to this Policy. The new version is published on the Website indicating the revision date.

Scheduled amendments take effect upon the expiry of 7 (seven) calendar days from the date of publication. Before they take effect, a User who does not agree with the amendments may stop using the Service and withdraw their assets.

Amendments arising from the requirements of applicable law, orders of competent public authorities, requirements of Partner Exchanges or Liquidity Providers, as well as the need to eliminate threats to the security of the Service, take effect from the moment of publication. In this case, a User who does not agree with the amendments may stop using the Service and withdraw their assets, except in the cases provided for in clause 2.4 of this Policy and clause 10.6 of the User Agreement.

Continued use of the Service after the amendments take effect constitutes the User's acceptance of the new version.

8. Governing Law, Language and Contacts

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

8.2. Prevailing Language of the Policy

This Policy has been drawn up in the English language. Versions in other languages are provided solely for the convenience of Users. In the event of discrepancies between the English version and a version in another language, the English version shall prevail.

8.3. For all questions related 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: via Telegram bot @office_app_support_bot