1. Introduction

1.1. The Anti-Money Laundering and Know Your Customer Policy (hereinafter the "AML/KYC Policy") of OKpays.com is aimed at preventing and mitigating the potential risk of OKpays.com being involved in any illegal activity, including money laundering and the financing of terrorism.

1.2. This AML/KYC Policy forms an integral part of the Terms of Service and applies to every User and every exchange operation carried out through OKpays.com.

1.3. OKpays.com bases its measures on international standards, including the recommendations of the Financial Action Task Force (FATF).

2. Purpose of Internal Regulation

2.1. OKpays.com adheres to the best practices and measures in the field of combating money laundering and the financing of terrorism (AML/CFT). The purpose of these measures is to demonstrate that OKpays.com takes seriously any attempt to use its services for illegal purposes.

2.2. OKpays.com continuously monitors all transactions and updates its electronic systems and internal procedures in line with new regulatory requirements, and provides regular AML training to its staff.

3. Caution and Prohibited Use

3.1. OKpays.com warns its Users against using its services for illegal activities such as money laundering, terrorist financing, fraud, and the purchase of prohibited goods and services.

3.2. OKpays.com, its administration, employees, and domain owners are not responsible for any misuse of its services by third parties or for any damages associated with such misuse.

4. General Requirements

4.1. The sender and the recipient of a payment must be the same person. Transfers to or from third parties are strictly prohibited.

4.2. All contact information and personal data provided by the User must be current and accurate.

4.3. It is strictly forbidden to use anonymous proxy servers, VPNs, Tor, or any other anonymous internet connection to create transactions on OKpays.com.

5. Risk-Based Approach and Risk Score Model

5.1. OKpays.com applies a risk-based approach to combating money laundering and terrorist financing, ensuring that preventive measures are proportionate to the risks identified for each User and each transaction.

5.2. Every incoming and outgoing cryptocurrency transaction is screened to determine a Risk Score expressed as a percentage from 0% to 100%. OKpays.com uses WhiteBIT as its AML analyzer to screen transactions and determine the Risk Score.

5.3. Based on the Risk Score, transactions are classified into the following risk levels:

• Low risk: a Risk Score from 0% to 30%. The transaction is processed normally
• Medium risk: a Risk Score from 31% to 49%. The transaction may be subject to additional review
• High risk: a Risk Score from 50% to 100%. The transaction is automatically held and subject to enhanced due diligence

5.4. The following are considered high-risk sources of funds: darknet marketplaces, ransomware, stolen coins, scams and fraud, mixers and tumblers, financing of terrorism, sanctioned entities and jurisdictions, and any other source prohibited by applicable law.

5.5. A transaction is automatically blocked and held for review when its Risk Score reaches 50% or higher, or when the share of funds originating from the prohibited sources listed in clause 5.4 reaches or exceeds 10%. Funds connected to sanctions, terrorist financing, or child sexual abuse material are blocked at any level of exposure.

5.6. OKpays.com reviews and updates the Risk Score model, its threshold values, and the list of analyzers periodically to reflect changes in regulation and in the typologies of financial crime.

6. Customer Due Diligence, KYC and Source of Funds

6.1. Customer due diligence is an international standard for preventing illegal activity. OKpays.com implements its own verification procedures in strict compliance with AML standards and the Know Your Customer ("KYC") procedure.

6.2. In accordance with the Risk Score model, OKpays.com may request the User to provide reliable and independent documents and information as part of the KYC and Source of Funds ("SoF") procedures. The following materials may be requested:

• Proof of identity: a government-issued international passport, a government-issued identity card, or a government-issued driving licence
• A selfie (photograph) of the User holding their identity document
• Proof of address: a utility bill or bank statement no older than 3 months (paper or electronic versions are accepted)
• In individual cases, and only for card payments: a photograph of the payment card and a selfie of the User holding the card
• In individual cases, and for large amounts: a photograph of the User holding a printed or handwritten declaration
• Source of Funds evidence: documents confirming the lawful origin of the funds or cryptocurrency, such as bank statements, cryptocurrency exchange withdrawal histories, payslips, or contracts

6.3. All documents must be provided in good quality, with all text legible and without any modification or editing. Documents that are altered, incomplete, or illegible will be rejected, and new copies will be requested.

6.4. OKpays.com verifies the authenticity of the documents and information provided through lawful methods, and reserves the right to investigate any case where a User's identity or activity is deemed suspicious.

6.5. OKpays.com reserves the right to verify a User's identity and source of funds on an ongoing basis, and may request up-to-date documents even from Users who were verified in the past.

6.6. User identification information is collected, stored, shared, and protected strictly in accordance with the OKpays.com Privacy Policy and applicable law.

6.7. OKpays.com may request additional information and/or documents from the User at any time, and may block or restrict access to the User's account if the required compliance information has not been provided.

7. Verification Stages and Timeframes

7.1. AML verification is carried out in the following stages:

• Stage 1 - Automated screening: performed automatically for every transaction, usually within a few minutes and no later than 1 hour
• Stage 2 - Request for information: where a transaction is held, the User is notified and asked to complete the KYC/SoF procedure. The User must submit the requested documents within 7 working days
• Stage 3 - Review: the submitted documents and the transaction are reviewed within 1 to 5 business days after all requested documents have been received
• Stage 4 - Decision: the User is informed of the outcome, and the funds are either released and exchanged or returned, in accordance with section 8

7.2. A standard AML review is normally completed within 14 business days of receiving complete documents. Complex cases that require additional analysis, third-party confirmation, or cooperation with law enforcement may take longer; in such cases the User is kept informed.

8. AML-Related Holds and Return of Funds

8.1. Where a transaction is held for AML reasons, the User is given the opportunity to complete the KYC/SoF procedure described in sections 6 and 7.

8.2. If the User successfully passes the KYC/SoF procedure, or if there is no evidence that the funds are linked to money laundering or other illegal activity, the transaction is completed or the funds are returned with only the network (blockchain or transfer) fee deducted. No additional exchange or refund fee is charged in such cases.

8.3. Where a refund fee applies in an AML-related case, it will not exceed 5% of the blocked amount and will not exceed the equivalent of 100 USD.

8.4. Funds released or returned in AML-related cases are processed within 5 business days from the date of the decision.

8.5. If the funds are confirmed to be connected to money laundering, terrorist financing, or other illegal activity, OKpays.com may withhold the funds, refuse the transaction, and report the case to the relevant authorities in accordance with applicable law. In accordance with international law, OKpays.com is not obliged to notify the User of a suspicion of criminal activity.

8.6. OKpays.com may withhold the crediting or release of funds until the required documentation has been provided, in accordance with its AML/CFT procedures and applicable laws.

9. Cryptocurrency Address Policy and Clean Funds

9.1. To minimise the risk of Users receiving high-risk funds, OKpays.com uses only labelled, verified, and clean cryptocurrency addresses.

9.2. OKpays.com always generates a unique, one-time deposit address for each order, and subsequently consolidates funds using an algorithm designed to prevent the transaction chain from being marked as high risk through a connection with a high-risk source. Payouts are made only from addresses that are labelled as safe and verified in a reputable AML analyzer.

9.3. Incoming funds identified as high risk under section 5 are not mixed with clean reserves and are handled separately in accordance with this policy.

10. Preliminary AML Check and User Consent

10.1. Before creating an order, the User is given the opportunity to carry out a preliminary AML check of their wallet or transaction, free of charge or for a fee, using valid AML analyzers consistent with the Service's Risk Score model.

10.2. Following the preliminary check, the User may either:

• submit the results to the operator for risk assessment and recommendations before the exchange is carried out; or
• consciously decline the check by confirming acceptance of the associated risks through a dedicated checkbox accompanied by an appropriate notice

10.3. The User's acceptance of this AML/KYC Policy and the Terms of Service must be confirmed through a separate, dedicated checkbox before an order is created. The display of a notice alone is not sufficient; active consent through the checkbox is required.

11. Record Keeping

11.1. OKpays.com maintains accurate and up-to-date records of all transactions and customer identification information for a minimum of 10 years, in compliance with regulatory requirements.

11.2. These records are kept confidential and secure and are disclosed only to authorized parties in accordance with applicable laws and regulations.

12. AML Compliance Officer and Compliance Function

12.1. This AML/KYC Policy is overseen by a designated AML Compliance Officer who is responsible for ensuring that OKpays.com implements and enforces effective measures to prevent money laundering and terrorist financing.

12.2. The responsibilities of the AML Compliance Officer include:

• collecting User identification information and verifying the identity of Users
• developing and updating internal policies and procedures for preparing, reviewing, submitting, and storing all required reports and records
• monitoring transactions and investigating significant deviations from normal activity
• maintaining a records-management system for the storage and retrieval of documents, files, forms, and logs
• regularly updating the risk assessment to identify vulnerabilities in the AML/KYC program
• providing law enforcement agencies with information required by applicable law

12.3. The AML Compliance Officer is authorised to communicate and cooperate with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.

12.4. OKpays.com maintains a dedicated compliance function to support the AML Compliance Officer in the day-to-day operation of this policy. This function comprises an in-house compliance team, supported by outsourced compliance services provided by partner wallet and payment companies.

13. System Functions and Sanctions Screening

13.1. OKpays.com operates a comprehensive compliance system that collects data, filters transactions, keeps records, manages investigations, and produces reports.

13.2. The system performs daily screening of Users against recognized sanctions and watch lists (for example, OFAC), consolidates transactions across multiple data points, places Users on watch lists and denies service where necessary, opens investigation cases, sends internal notifications, and files mandatory reports where applicable.

14. Behavior Analysis

14.1. OKpays.com assesses Users not only by verifying their identity but also by analysing their transactional behavior. Data analysis is an essential tool used to assess risk and detect suspicious activity.

15. Multiple Accounts Policy

15.1. Each User may hold only one account. Holding more than one account is prohibited.

15.2. If a User is found to hold more than one account, all such accounts will be temporarily disabled. The User will be asked to choose which account will remain active; the others will be permanently blocked.

15.3. If a User is found to be creating multiple accounts in order to bypass the limits set for a particular payment method, OKpays.com reserves the right to request additional verification. If the User cannot provide the requested information, OKpays.com will return the payment to the original sender, retaining any incoming and outgoing transaction fees.

16. Confidentiality and Disclosure

16.1. OKpays.com is committed to maintaining the confidentiality of client information in accordance with its Privacy Policy.

16.2. OKpays.com and its employees are bound by confidentiality obligations with respect to any information related to questionable transactions. This obligation also applies to Users and to third parties who may have access to transaction information.

16.3. The confidentiality obligation remains in effect even after an employee's or contractor's relationship with OKpays.com has ended. It does not apply where disclosure is required by law, including disclosures to law enforcement and government agencies.

17. Disclaimer of Liability

17.1. OKpays.com does not accept legal responsibility for the use of its services for money laundering, terrorist financing, or the purchase of prohibited goods or services. The Service is nevertheless committed to taking all necessary measures to prevent such use.

17.2. By making an exchange, the User agrees to this AML/KYC Policy and the Terms of Service and undertakes to comply with them.