AML Policy
AML / KYC Policy
AML/KYC Policy
Introduction
This document provides an overview of the “Know Your Customer” (KYC) and “Anti-Money Laundering” (AML) policy standards and defines the approach of the Dmoney service to preventing the use of the platform for money laundering purposes when interacting with users.
The purpose of the AML/KYC policy is to prevent both intentional and unintentional use of the Dmoney service for illegal purposes, including the legalization of proceeds derived from criminal activity. Within the framework of this policy, the service takes reasonable measures to identify users and beneficial owners, determine the source of funds, understand the nature of the client’s activities, and assess the legitimacy of transactions, which allows for effective risk management.
This document describes the main principles and AML control procedures used by Dmoney to ensure transaction security and compliance with international standards (including 5AMLD/6AMLD), as well as applicable anti-money laundering legislation.
Dmoney strives to provide a high level of protection for users against fraud and abuse in the field of crypto assets. In its operations, the service adheres to current FATF recommendations, requirements of the European Parliament, and generally accepted financial regulatory standards. The compliance policy is aimed at identifying funds related to illegal activity, as well as protecting users affected by hacks, malware attacks, or other unlawful actions.
As part of the AML approach, the service uses a set of measures, including internal regulations and modern software solutions that enable real-time transaction monitoring and detection of suspicious activity.
The AML/KYC policies, procedures, and internal control system of Dmoney are developed in accordance with current regulatory requirements and are subject to regular review and updates to ensure relevance in light of legislative changes and the development of the service.
1. Customer Identification Procedure (CIP)
The Customer Identification Procedure (CIP) applies to transactions that are considered potentially suspicious based on the internal risk assessment system.
As part of CIP, the Dmoney service collects identification information about users, applies risk-based identity verification methods, records the obtained data, as well as verification methods and results. Users subject to CIP are notified of the need to provide information to confirm their identity.
1.1 Warning
Dmoney warns users that it is prohibited to use the platform for:
- money laundering
- terrorist financing
- fraud of any kind
- purchasing prohibited goods and services
Dmoney, its administration, and employees are not responsible for illegal actions of third parties or for any losses resulting from misuse of the service.
1.2 Requirements
To prevent illegal operations, Dmoney establishes the following mandatory conditions:
- the sender and the recipient of funds must be the same person; using the service in the interests of third parties is prohibited
- all contact and personal data provided by the user must be accurate and up to date
- the use of VPNs, Tor, proxies, and other anonymization tools when creating requests is prohibited
1.3 Verification Procedures
User verification is a mandatory element of international AML/KYC practice.
Dmoney reserves the right to request documents and information from reliable sources, including but not limited to:
- identity documents
- passports
- bank documents
Dmoney takes the necessary measures to verify the authenticity of the provided data, including the use of lawful additional verification methods. The service reserves the right to conduct enhanced due diligence on users whose activity or provided data raise suspicion.
Verification may be carried out on an ongoing basis, especially in cases of changes in user data or detection of unusual activity. The service also reserves the right to request documents again, even if the user has previously completed verification.
The collection, processing, and storage of personal data are carried out in accordance with the Dmoney Privacy Policy.
Based on the results of verification, the service may refuse to provide services if there are signs of illegal activity.
Users who use bank cards must, if necessary, undergo additional verification, including confirmation of card ownership.
Dmoney also reserves the right to request information about the source of funds or crypto assets to confirm their legality.
1.4 Responsible Officer
Dmoney appoints an authorized person (AML Officer) responsible for compliance with AML/KYC requirements.
Their responsibilities include:
- monitoring the implementation of AML/KYC policy
- collecting and verifying user identification information
- developing and updating internal procedures and regulations
- monitoring transactions and identifying deviations
- organizing document storage and record-keeping
- regular risk assessment
- interaction with government and law enforcement authorities
The authorized person has the right to interact with competent authorities on issues related to preventing money laundering, terrorist financing, and other illegal activities.
2. Behavioral Analytics
Dmoney verifies users not only through identity verification but also, importantly, through analysis of their behavior when conducting transactions.
Data analysis is used as a risk assessment tool and for detecting suspicious activity, allowing timely response to potential threats.
3. General Provisions and Purpose of AML Policy
We strive to ensure maximum transparency and security of financial transactions. The AML/KYC policy of the Dmoney service is aimed at minimizing the risks of using the platform for illegal purposes, including:
- money laundering
- terrorist financing
- fraud
- other financial crimes
By creating a request on the platform, the user automatically confirms agreement with the terms of this policy.
4. AML Analyzer and Risk Assessment Principles (Risk Score)
To automatically verify cryptocurrency addresses and transactions, the Dmoney service uses data from specialized AML analytics providers, including:
- Rapira
- BitOk
- GetBlock
Based on this data, a final Risk Score is generated — an indicator of the risk level for each transaction. The system evaluates the source of funds by analyzing transaction history for links to high-risk categories such as:
- Darknet platforms (Dark Service, Dark Market)
- Mixing services (Mixer)
- Fraudulent and hacking schemes (Scam, Hacked, Stolen Coins, Phishing, Fraud)
- Sanctions lists (Sanctions) and terrorist financing
- Illegal gambling (Gambling)
5. Risk Thresholds and Service Actions
- Low risk (0–30%): the transaction is processed automatically in standard mode
- Medium risk (30–60%): the transaction may be flagged for additional monitoring; in some cases, the service may request explanations or documents to clarify the source of funds
- High risk (over 60%): the transaction is automatically suspended; further decisions are made after manual review by an AML Officer
The basis for blocking may be either a high overall Risk Score or the presence of specific “red flags” (for example, links to stolen coins or sanctioned addresses), even if the total score does not exceed the threshold.
6. AML Check Stages and Timeframes
- Automatic scoring — performed instantly when a request is created.
- Detailed analysis — if risk factors are triggered, the request is sent to an AML Officer for manual review.
- Review period — approximately 1 to 72 hours from the moment additional information is requested from the user. In complex cases involving merchants or liquidity providers, the timeframe may be extended.
7. Terms and Conditions for Refunds
- If verification is successful: funds are returned to the sender or credited to the recipient in full, minus the standard service fee.
- In case of high risk:
- If the user provides sufficient proof of lawful origin of funds (KYC, Source of Funds) and receives AML Officer approval, the transaction is unblocked. The service may charge an additional fee for enhanced due diligence — up to 5% of the blocked amount, but not exceeding $100 equivalent.
- For bona fide users whose funds are not linked to money laundering after KYC and Source of Funds verification, the exchange fee remains unchanged; only the network fee is deducted in case of a refund.
- If the user fails to provide the requested documents or the data is deemed insufficient, the service reserves the right to refuse the transaction.
Important: refunds are not possible if funds are frozen at the request of competent authorities (e.g., as part of a criminal investigation) or if the sender used sanctioned platforms (e.g., Garantex, Tornado Cash).
8. Recommendations for Users
To reduce the risk of blocking, we strongly recommend that users independently check the AML status of sender or recipient addresses before transferring funds using available tools.
This helps assess potential risks in advance and make informed decisions when conducting transactions.
9. Actions in Case of Refusal to Verify
If a user refuses to undergo KYC verification or fails to provide the requested documents within the specified timeframe, the Dmoney service acts in accordance with applicable laws and internal procedures, which may include:
- Refund of funds: the service initiates a refund to the original address within a reasonable period not exceeding 10 business days from the end of the document submission period. Network or payment provider fees may be deducted as described in Section 7.
- Reporting to authorities: in cases предусмотренных законом or when there are reasonable suspicions of illegal activity, the service (or its infrastructure partner) may file a Suspicious Activity Report (SAR) with the competent financial intelligence unit (FIU).
10. Confidentiality
The Dmoney service guarantees client confidentiality in accordance with its Privacy Policy.
Dmoney employees are required to maintain confidentiality of any facts discovered during the investigation of suspicious transactions. This obligation also applies to users and third parties who may have received information about a transaction.
The confidentiality obligation of employees remains in force after the termination of their employment or contractual relationships with Dmoney, including reassignment to another position. Disclosure of information to government or law enforcement authorities as permitted by law does not constitute a breach of confidentiality.
The confidentiality obligation, provided that the use of information is limited to preventing money laundering and terrorist financing, may not apply to data exchange between financial institutions within a consolidated group cooperating with Dmoney.
11. Conclusion
Dmoney service is not legally responsible for the use of the platform for money laundering, terrorist financing, or the purchase of prohibited goods and services. Nevertheless, the service takes all possible and reasonable measures to prevent any attempts to use Dmoney for illegal purposes.