Terms and Definitions

BMBExchange – a trademark of the system providing Users with the possibility to exchange digital and electronic currencies.

Service – a system providing internet services for the exchange, sale, and purchase of digital and/or electronic currencies.

User – any individual using the services of BMBExchange.

Digital Currency – Bitcoin, Litecoin, Ethereum, and any other currencies based on blockchain technology.

Electronic Currency – funds held in user accounts of electronic payment systems (Qiwi, Yandex Money, etc.).

Service Services – assistance in conducting P2P transactions between individuals for the purchase, sale, and exchange of digital currencies, as well as other services, information about which is posted on the Service showcase.

Card Verification – verification of the ownership of a card (or account) by its holder. The conditions for verifying ownership are established by the Service and are carried out once for each new User account (card).

Money Laundering – giving a lawful appearance to the possession, use, or disposal of funds or other property obtained as a result of committing a crime. BMBExchange strictly follows laws prohibiting us or any of our employees from knowingly engaging or attempting to engage in any activity related to money laundering. Our anti-money laundering policy is aimed at increasing the security of clients and the services provided by the Service.

Terrorist Financing – the intentional provision or collection, by any means, directly or indirectly, of funds with the intention that such funds be used, or in the knowledge that they will be used, to carry out terrorist acts.

Anti-Money Laundering Policy (AML Policy)

Effective Date: 02.08.2023

Last Updated: 27.07.2024

This AML Policy (hereinafter referred to as the “Policy”) regulates the activities of BMBExchange in relation to combating money laundering and its involvement in combating money laundering and the financing of terrorist activities.

Measures Taken to Comply with the AML Policy

The Administration of the BMBExchange Service, understanding the public danger of crimes related to money laundering and terrorist financing, has developed a set of organizational and legal measures in order to comply with national legislation and the requirements of the intergovernmental organization FATF.

European AML regulation is based on a number of legislative directives. In particular, the EU issued the Sixth Anti-Money Laundering Directive (6AMLD), which entered into force on December 2, 2018.

Other legislative acts aimed at combating the legalization of proceeds obtained by criminal means and terrorist financing include:

5th Anti-Money Laundering Directive ((EU) 2018/843);
Proceeds of Crime Act 2002;
Terrorism Acts of 2000 and 2001;
Counter-Terrorism Act 2008;
Treasury Sanctions Notices.

Application of KYC Policy (Know Your Customer)

Mandatory identification of Users who are allowed to carry out transactions on our Service.

For User verification, the Administration has the right to request the following data:

Take a photograph (“selfie”) with an identity document: scanned copies of the front and back sides of an official photo ID, i.e., a valid passport, driver’s license, or other national identity document;
Confirm place of residence: an official document issued within the last 3 months clearly indicating the client’s name and address provided during registration on the BMBExchange website. This may be a utility bill (water, electricity, or landline telephone) or a bank statement. The copy must include: full name, full residential address, date of issue (within the last 3 months), name of the issuing authority with official logo or seal;
Provide a copy of the front and back sides of a bank card and/or a photograph of your bank card taken against the background of the main page of the Service (service showcase). For confidentiality and security purposes, only the last 4 digits of your credit card must be visible. It is allowed to hide the 3 digits on the back side of the card (CVV code).

The Administration of the BMBExchange Service will take steps to confirm the authenticity of the documents and information provided by Users. Identification information will also be verified using secondary sources, and the Administration reserves the right to continue investigating cases in order to obtain full confidence in the authenticity of the provided documentation.

The Administration of the BMBExchange Service reserves the right to conduct ongoing monitoring of User data, especially in cases where identification information has been changed or the User’s activity appears suspicious (unusual for that particular User). In addition, the Administration reserves the right to request updated documents from Users even if they have previously passed verification.

Continuous monitoring of operations carried out through the Service. We exercise constant control over all requests created on the BMBExchange website. The Administration notifies Users of the prohibition on carrying out exchange transactions from third parties using their account.

Appointment of a responsible person (MLRO — Money Laundering Reporting Officer) exercising supervisory powers for the implementation of this Policy.

Application of a risk-based approach (RBA — Risk-Based Approach). We implement different levels of verification depending on the volume and number of transactions carried out by the User.

Improvement of professional skills and knowledge of the BMBExchange team employees in terms of compliance with the Policy requirements.

Interaction with state authorities in cases established by law. In the event of an official request from law enforcement or judicial authorities, we will be obliged to provide the requested information. The Administration also has the right to provide data requested by official representatives of payment systems.

Enhancement of the security of the BMBExchange software. We care about the reliability and security of your transactions. In this regard, we continuously improve our IT department, whose main task is to protect the website from unauthorized access by intruders.

The Administration of the BMBExchange Service, in cases prescribed by law, may require regulatory proof of the source of fiat money and/or cryptocurrency to ensure that the sources of Funds used by the Client for exchange are lawful. As a document confirming the source of Funds, a bank statement for fiat funds or a video demonstrating wallet transaction details for cryptocurrency may be requested.

In accordance with this Policy, the Service Administration will:

monitor all transactions. The Administration reserves the right to ensure the submission of reports on suspicious transactions to the appropriate law enforcement authorities through the Responsible Officer;
request from the User any additional information and documents in the event of suspicious transactions, as well as at the request of a regulator (a regulator may be an exchange, government authority, or other organization having the appropriate legal grounds);
suspend or terminate a User account if there is reasonable suspicion that such User is involved in illegal activities.

The above list is not exhaustive, and the Responsible Officer will monitor User transactions on a daily basis in order to determine whether such transactions should be reported and considered suspicious or considered bona fide.

Country of Residence

This Policy defines our AML risk criteria. To reduce this risk, the Administration of BMBExchange does not accept clients residing in the following countries with an increased risk criterion.

Sources used for categorization:

Transparency International;
Know Your Country;
FATF list of high-risk jurisdictions;
EU list of high-risk jurisdictions;
Countries where digital assets are prohibited or restricted;
Countries where digital assets are not prohibited;
Countries subject to UN Security Council sanctions regimes.

All clients residing in the countries listed below are prohibited from being serviced by BMBExchange and may not be accepted as Users.

Any clients from these countries will be refused service, and any funds will be returned to the source.

Full list of prohibited jurisdictions:

United States
Afghanistan
Albania
Angola
Algeria
Barbados
Bolivia
Botswana
Burma (Myanmar)
Burundi
Cambodia
Central African Republic
Chad
Congo
Conakry
Côte d'Ivoire
Crimea (Ukraine)
Cuba
Democratic People’s Republic of Korea (DPRK)
Ecuador
Egypt
Equatorial Guinea
Eritrea
Ghana
Guinea-Bissau
Haiti
Guyana
Iran
Iraq
Lao People’s Democratic Republic
Lebanon
Libya
Mali
Morocco
Myanmar
Nepal
Nicaragua
North Macedonia
Pakistan
Panama
Qatar
Saudi Arabia
Somalia
South Sudan
Sudan
Syria
Tunisia
Uganda
Vanuatu
Venezuela
Yemen
Zimbabwe
Jamaica

The Administration of BMBExchange also does not accept clients from disputed territories, as they do not provide generally recognized official documents, including:

Pridnestrovian Moldavian Republic
Republic of Abkhazia
Republic of Somaliland
Republic of South Ossetia
Turkish Republic of Northern Cyprus
Republic of China (Taiwan)
Republic of Kosovo
Sahrawi Arab Democratic Republic
Republic of Artsakh

The Administration of BMBExchange also informs that it does not work with client funds related to prohibited services, such as:

Garantex
BeriBit
HODLHODL
SkyBtc Banker
Black Sprut
Wasabi Wallet
Bitzlato
Hydra
Tornado Cash
OMG!OMG!
MEGA DARKNET MARKET
FreeBitcoin
Casinos
Gambling
1xBet

If a transaction has a risk level exceeding 50%, the deposit may be frozen until KYC identity verification is completed, followed by a return to the sender.

KYT Policy (Know Your Transaction)

Effective date: 02.08.2023

Updated: 27.10.2023

The KYT Policy (Know Your Transaction) is aimed at identifying the counterparty to a transaction in the event of a precedent where the Service has reasonable suspicions that the Client is using BMBExchange for improper purposes.

Such a precedent may arise if the Service suspects the Client of unlawful actions that may be qualified as laundering or attempted laundering of digital assets obtained unlawfully, or if the funds have an evidently criminal origin. For these purposes, the Service has the right to use any lawful information, third-party digital asset origin analysis tools, as well as its own screening system developments. Any content of high-risk assets as a result of verification may become grounds for suspicion.

In this case, BMBExchange reserves the full right to:

Require the Client to provide additional information disclosing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
Block the account and any operations related to the Client and transfer to financial supervisory and/or law enforcement authorities at the place of registration of the Service and, if necessary, at the Client’s place of registration all information and documents related to the incident;
Require documents confirming identity, physical existence, registered address, and solvency;
Return digital assets only to the details from which the transfer was made or switch to other details after a full security check by the Service, if it was possible to verify the lawful origin of the Client’s funds;
Refuse withdrawal of funds to third-party accounts without explanation;
Retain the Client’s funds until the incident is fully investigated;
Monitor the entire transaction chain in order to identify suspicious transactions;
Refuse to provide services if there are reasonable suspicions regarding the legality of the origin of digital assets and retain funds in special Service accounts;
Refuse to provide services if there are reasonable suspicions regarding the legality of the origin of digital assets and retain funds in special Service accounts in cases where it is impossible to trace the entire transaction chain from the moment of their origin.

Conditions for Refund of Funds Suspended Following AML Transaction Analysis:

Refund of funds is carried out after a full verification by the Service’s security department, which may include detailed verification of the sender.
Refund is carried out minus a commission of up to 5% of the transaction amount to cover labor costs for processing the request and organizing the refund.
The refund, subject to approval by the Service, will be processed within 7 (seven) calendar days starting from the date the User was notified of the Service’s decision regarding the refund request.
When arranging a refund, after passing verification, the User is obliged to confirm the details for receiving the refunded funds.

AML/KYC Policy

Terms and Definitions

Anti-Money Laundering Policy (AML Policy)

Application of KYC Policy (Know Your Customer)

Country of Residence

KYT Policy (Know Your Transaction)