This Policy establishes a set of rules, measures, and procedures aimed at preventing the laundering of proceeds obtained through unlawful means, terrorist financing, as well as identifying clients and monitoring transactions carried out through the Service. The application of this Policy is intended to protect MULTIVAL and its Users from involvement in unlawful activities. Each Application is subject to a mandatory AML check. Where necessary, prior to transferring funds, the User is entitled to independently and in advance verify whether their cryptocurrency wallet complies with AML requirements by using the AML checker. If the wallet address is unknown to the User, or the User is unable or refuses to undergo a preliminary AML check, and the aggregate AML risk exceeds the threshold of 60%, the exchange shall be suspended and the funds shall be refunded less the network fee in accordance with the procedure set forth in the User Agreement.

1. Key Terms

MULTIVAL — an online platform intended for the exchange, purchase, and sale of cryptocurrencies and other digital assets. User — an individual or legal entity using the MULTIVAL service. Cryptocurrency — a digital medium of exchange operating on the basis of blockchain technology. Electronic Currency — monetary funds circulating within electronic payment systems. Money Laundering — actions aimed at giving a lawful appearance to the possession, use, or disposal of funds obtained through criminal activity. Terrorist Financing — the provision or collection of funds with the intention that they be used to commit terrorist acts.

2. Preliminary AML Check of a Cryptocurrency Wallet

Prior to submitting an exchange Application, the User is entitled to independently verify the reliability of their cryptocurrency wallet by using the AML checker. To use this functionality, the User must register on the website and purchase a package of checks in the Personal Account.

2.1. Registration on the Website

Having an account is a mandatory condition for using the AML checker.

• Click the "Registration" button located in the upper-right corner of the website.
• Provide the following information:
  • email address;
  • password.
• Complete the registration procedure by following the link sent to the specified email address.

After the registration is confirmed, the User is granted access to the Personal Account.

2.2. Purchase of an AML Check Package

AML checks are provided on a paid basis under a package-based system.

1. Log in to the Personal Account.
2. Click the «Buy checks» button.
3. Select the required package of checks.
4. Click the «Proceed to payment» button.
5. The system will generate an address for making a deposit. Send the payment to the specified address. After the deposit is successfully credited, the number of available checks will be displayed in the Personal Account, after which they may be used immediately for AML analysis of wallets.

2.3. Conducting an AML Check

1. In the Personal Account, open the «AML Checks» section and click the «New Check» button.
2. Enter the address of the cryptocurrency wallet from which the funds are intended to be sent.
3. Select the relevant network: BTC, ETH, TRC-20, etc.
4. Click the «Check» button. The system will deduct 1 check from the purchased package and provide the analysis result.

2.4. Providing the Result to the Operator

Upon completion of the AML check, the result is automatically sent by the system to the User's email address. The further procedure depends on the established risk level:

• if the risk level does not exceed 60%, the User is entitled to use the relevant wallet for the exchange without taking any additional action;
• if the risk level exceeds 60%, the User must provide the check result to the operator via the online chat on the website.

The message must specify:

• the address of the checked wallet;
• the date on which the check was conducted;
• a brief description of the check result.

The operator reviews the information provided and informs the User whether funds may be sent from the relevant wallet. Important: notifications concerning an elevated risk level must not be ignored, as taking them into account is a mandatory requirement of the Service's AML Policy.

3. Policy Objectives

• Preventing the use of the platform for unlawful purposes.
• Ensuring compliance with applicable legal requirements and international standards.
• Enhancing User security and maintaining the Company's reputational resilience.

4. Policy Components

4.1. AML/CTF

• Client identification and verification of the source of funds.
• Transaction monitoring for the purpose of detecting suspicious activity.

4.2. KYC

• Collection and verification of the client's personal and financial information.
• Contact and personal information provided by the User when submitting an Application must meet the requirements of completeness, accuracy, and relevance.
• MULTIVAL ensures the protection, storage, and processing of such data in accordance with the User Agreement and applicable law.
• Users' personal data is not transferred to third-party AML providers. For transaction analysis purposes, automated blockchain analytics tools may be used, whereby only technical transaction data is processed, namely cryptocurrency wallet addresses and transaction hashes, without transferring the User's personal data.

4.3. KYT

• Analysis of transactional activity to identify fraudulent and other unlawful operations.
• Suspension of suspicious transactions until information confirming their lawful nature is obtained.
• Verification of the source of funds.

4.4. Handling High-Risk Operations

The Service uses automated blockchain analytics systems designed to identify signs of suspicious activity and transaction risk markers. During the check, transaction risk indicators are analyzed, including potential links to high-risk sources, fraudulent schemes, sanctioned services, and other categories of suspicious activity. If, based on the results of the automated check, the aggregate risk level exceeds 60% and a link is identified with high-risk sources specified in Section 4.5 of this Policy, the transaction may be temporarily suspended for additional review and for a decision to be made regarding the refund of funds to the User less the network fee. If a decision is made to refund the funds, the relevant operation may take up to 7 (seven) business days. The status of the operation is determined on the basis of a comprehensive automated analysis of transactional data and the results of the AML/KYT check.

4.5. Categories of High-Risk Sources

MULTIVAL reserves the right to block funds received from exchanges included in sanctions lists or classified as «high-risk». At present, such platforms include: Black Sprut, BTC-e, Chiper Mixer, DuelBits, FreeBitcoin, Gandhiji.io, Hydra, NVSPC, Roobet, Tornado, WEX Exchange, Yolo Group, OMG!OMG!, Garantex, Commex, Tornado Cash, 1xBit, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, MEGA DARKNET MARKET, Primedice, Darknetone, Wasabi Wallet, DuckDice, Doubleway, Stake, Stolen Coins, Fraudulent Exchanges, Terrorism Financing, Bitzlato, Bitpapa.com, NetEx24.net, Trocador.app, Anonexch.io, Cryptomus, nobitex.ir, meer.kg, 1xbet, Aifory.pro, terminal.cash, SkyCrypto.net, FlashObmen.com, 60cek.net, hd-change.com, CoinBlinker.com, Metka.cc, AlfaBit.org, Heleket, payeer.com, Vexel, Fun Pay, Web Money, Freekassa, Yobit, exmo.com, exmo.me, Crypto Cloud, Cripta, BitBits, Nix Money, Bixter, freekassa.ru, kassa.cc, CoinStart, Prostocash, arvix.pro (abcex.io), heleket.com, xRocket.tg, CryptoCloud, weiss.bet, BTC-e / FinCEN, Sinbad, OFSI Huobi Global S.A. (HTX.com), as well as platforms from other sanctioned countries and services focused on anonymity and privacy. This list may be supplemented. Risk categories: Sanctions, Terrorism, Darknet, Ransomware/Malware, Mixing, Child Abuse, Stolen Funds, Scam/Fraud, Protocol Privacy, Bridge, Decentralized Exchange, Gambling. MULTIVAL shall not be liable for funds received from the sources listed above and is entitled to provide the relevant information to competent authorities.

4.6. Procedure for Refunding Funds in the Event of an Unsuccessful AML Check

If, based on the results of the automated check, the aggregate risk level exceeds 60% and a link is established with high-risk sources listed in Section 4.5 of this Policy, the transaction may be temporarily suspended for additional review and for a decision to be made regarding the refund of funds to the User. Where an AML block is applied:

• up to 24 hours — to determine the final status of the check;
• up to 7 (seven) business days from the moment the wallet is received — to process the refund;
• in rare cases, the funds may be held for up to 30 (thirty) business days if completion of the AML/KYT check requires additional analysis, obtaining information from third parties, or completion of procedures by external AML providers or platforms involved in processing the transaction.

Fees and expenses upon refund The following may be withheld from the amount subject to refund:

• the actual blockchain network fee (Network fee);
• documented expenses of AML, payment, or other providers incurred in connection with the review, processing, or unblocking of the transaction;
• additional expenses associated with the refund — in an amount not exceeding 5% of the blocked funds, but not exceeding the equivalent of USD 100.

Technical requirements for USDT refunds. For refunds in the TRC-20, ERC-20, and BEP-20 networks, the address from which the funds were originally sent may need to hold the relevant native asset required to pay the network fee:

• TRX — for the TRC-20 network;
• ETH — for the ERC-20 network;
• BNB — for the BEP-20 network.

The recommended available balance of the native asset for covering the network fee is the equivalent of 3–5 USDT. If the native asset balance is insufficient, the User may be requested to top up the relevant address in advance by the amount necessary to process the refund.

5. Rights and Obligations of the Service

MULTIVAL reserves the right to:

• Suspend and block transactions.
• Request additional documents and proof of identity from the User.
• Require the User to undergo video verification for identity confirmation purposes.
• Provide relevant information to regulatory or law enforcement authorities.
• Refund funds to the account from which the deposit was made and terminate further interaction with the client.
• If the User does not contact the Service for more than 6 (six) months with a request for the refund of funds blocked as a result of AML checks conducted by third parties, including centralized exchanges whose wallets are used in the execution of the Application, MULTIVAL is entitled to independently determine the form of such refund: in USDT or in the relevant token, at the exchange rate applicable on the date the Application was submitted or at the exchange rate applicable on the refund date.