Money laundering (anti-money laundering – AML) is the act of transforming money or other monetary instruments derived from some illegal activity into money or investments that appear to be legitimate, so that their illegal source cannot be tracked.
Blocking of funds from platforms included in the sanctions lists
LeoExchanger does not accept deposits from the Garantex, DuelBits, FreeBitcoin, Gandhiji.io, Hydra, NVSPC, Roobet, Tornado, WEX Exchange, Yolo Group, Black Sprut, CommEx, BTC-e, Chiper Mixer, Stake, 1xBit, OMG!OMG!, DuckDice, Primedice, MEGA DARKNET MARKET, Wasabi Wallet, Bitzlato, Bitpapa.com, NetEx24.net,capitalist.net, trocador.app, anonexch.io, rapira.net, Darknetone and DoubleWay exchanges. All funds received to our account from the specified resources will be blocked.
Procedures and methods
The purpose of the range of anti-money laundering measures and procedures that LeoExchanger uses for accurate transactions is to ensure that customers using LeoExchanger services are equally identified by a single standard. This minimizes both their own risks and the risks of law-abiding clients being imprisoned in the illegal actions of third parties. LeoExchanger positions itself as a service that helps the RIAC organization in the fight against money laundering.
To minimize the risks associated with money laundering and terrorist financing, we strictly do not accept or send payments to third (i.e. not identified) parties. Each client, to which their own account is assigned, has the right to send or receive payments using only their own accounts, whether they are accounts in electronic payment systems, bank accounts, credit / debit cards. We reserve the right to refuse to process transactions at any stage if we suspect that the transaction is in any way related to money laundering or criminal activity.
Adhering to the AML policy, we have the right to make confirmations of the origin of funds if the cryptocurrency sent by you has a High Risk or is associated with illegitimate sources. To confirm the origin of funds, we ask you to fully answer the following questions:
- through which platform did the funds come to you?
If possible, provide screenshots of the sender’s wallet/platform withdrawal history, as well as links to both transactions in the explorer:
- for what service you received funds;
- how much the transaction was, as well as the date and time of its execution;
- through which contact person did you communicate with the sender of funds? If possible, please provide screenshots of the correspondence with the sender, where we can see the confirmation of the funds being sent.
Also, please provide the following materials:
- Photo of one of the documents (passport, ID-card or driver’s license).
- Selfie with this document and a sheet on which today’s date and signature will be written by hand.
Obligations of the service operator to comply with this policy
The obligations of the service operator to comply with the Anti-Money Laundering and Anti-Money Laundering policy:
- storage of the client’s transaction history for three years;
- monitor and identify suspicious transactions;
- providing information about the client and his transactions to law enforcement authorities upon appropriate official request;
- suspension of a suspicious transaction until the circumstances are clarified and return of suspicious funds to the account of the source of funds;
- refusing to perform a suspicious operation.
On the principle of compliance with the law and openness, the LeoExchanger partner – the WhiteBIT service – operates.
We draw your attention to the fact that the use of the Services, the Website, and the WhiteBIT Platform is subject to the requirements of international law and its regulation, entirely and without exception. The User agrees to comply with the requirements of the WhiteBIT User Agreement when buying, selling, sending, receiving, exchanging, or storing digital assets on the LeoExchanger Platform.
The principles of legality and openness enable the Exchange to ensure a high degree of security for our clients, thus excluding WhiteBIT’s involvement in any type of illegal activity. The Exchange conducts mandatory monitoring and risk assessment of all ongoing transactions and other customer activities, using internal procedures and author’s AML/CTF monitoring systems, allowing them to effectively and reliably counter the financing of terrorism and combat money laundering.
On the principle of compliance with the law and openness, the LeoExchanger partner – the WestWallet service – operates.
General Provisions
This Anti-Money Laundering Policy (“AML Policy”) describes the procedures and mechanisms used by the LeoExchanger Service to combat money laundering. The LeoExchanger Service adheres to the following rules:
- not to enter into business relationships with criminals and/or terrorists;
- not to process transactions that are the result of criminal and/or terrorist activities;
- not to facilitate any transactions related to criminal and/or terrorist activities;
Verification Procedures
LeoExchanger Service establishes its own verification procedures within the framework of anti-money laundering standards – the “Know Your Client” policy.
LeoExchanger Service users undergo verification procedure (provide state identification document: passport or identification card). LeoExchanger Service reserves the right to collect Users’ identification information for the purposes of the AML Policy. This information is processed and stored strictly in accordance with the LeoExchanger Privacy Policy.
LeoExchanger Service may also request a second document to identify the User: a bank statement or a utility bill not older than 3 months, which contains the full name of the User and his/her actual place of residence. This list of documents is not final and LeoExchanger service may request other documents.
LeoExchanger service checks the authenticity of documents and information provided by Users and reserves the right to receive additional information about Users who have been identified as dangerous or suspicious.
If the User’s identification information has been changed or his/her activity seems suspicious, the LeoExchanger Service has the right to request updated documents from the User, even if they have been authenticated in the past.
AML Policy Compliance Officer
The AML Policy Compliance Officer is a LeoExchanger employee whose responsibility is to ensure compliance with the AML Policy. Specifically:
- collecting User identification information;
- creating and updating internal policies and procedures for writing, reviewing, submitting and maintaining all reports required under existing laws and regulations;
- monitoring transactions and analyzing any significant deviations from normal User activity;
- implementing a records management systеm to store and retrieve documents, files, forms and logs;
- updating the risk assessment on a regular basis.
The AML Policy Compliance Officer has the right to interact with law enforcement agencies that are engaged in prevention of money laundering, terrorism financing and other illegal activities.
Transaction Monitoring
Monitoring of the User’s transactions and analysis of the obtained data is also a tool for risk assessment and detection of suspicious transactions (transactions in the high risk zone, risk of 60% or more or if present from 10% – Child Exploitation, Dark Market, Darknet Marketplace, Dark Service, Enforcement Action, Fraud Shop, Fraudulent Exchange, High-Risk Jurisdiction, Illegal Service, Illicit Actor/Organization, Mixer, Mixin, Ransom, Sanction, Sanctions, Scam, Stolen Coins, Terrorism Financing). In case of suspicion of legalization of funds or detection of suspicious transactions (transactions in high risk zone, risk from 60% or if present from 10% – Child Exploitation, Dark Market, Darknet Marketplace, Dark Service, Enforcement Action, Fraud Shop, Fraudulent Exchange, High-Risk Jurisdiction, Illegal Service, Illicit Actor/Organization, Mixer, Mixin, Ransom, Sanction, Sanctions, Scam, Stolen Coins, Terrorism Financing) LeoExchanger Service reserves the right:
- report suspicious transactions to the relevant law enforcement authorities;
- ask the User to provide any additional information and documents;
- verify and block User’s transactions;
- suspend, block or terminate the User’s account.
The above list is not exhaustive. The person responsible for compliance with the AML Policy monitors the Users’ transactions on a daily basis to determine whether they should be reported and treated as suspicious.
Upon positive verification of a transaction, a refund will be issued to the customer containing a 5% fee. Please note that LeoExchanger reserves the right to charge an additional fee of up to 15% of transactions if they have high risk indications of 50% such as: Child Exploitation, Dark Market, Darknet Marketplace, Dark Service, Enforcement Action, Fraud Shop, Fraudulent Exchange, High-Risk Jurisdiction, Ilegal Service, Illicit Actor/Organization, Mixer, Mixin, Ransom, Sanction, Sanctions, Scam, Stolen Coins, Terrorism Financing. This additional fee is applied to compensate for the additional analysis and risk mitigation measures required to process high-risk transactions.
When we verify a transaction, we may store the balance of that transaction at the original address where the transaction was sent or we may store a similar balance of that transaction at our cold wallet at a different address. This is a technological feature of our crypto-processing operation.
Risk assessment
In accordance with international requirements, LeoExchanger Service applies a risk-based approach to combat money laundering and terrorist financing. Thus, measures to prevent money laundering and terrorist financing are commensurate with the identified risks. This allows for efficient allocation of resources: they are used in accordance with priorities and the greatest attention is paid to the greatest risks.
Assets cannot be recovered if the assets have been requested by competent authorities or seized/blocked by other agencies of any jurisdiction (in this case, the blocked asset may be treated as physical evidence).
If you have any questions, please contact us via the Feedback Form.
