Edition of 15.10.2026

1. General Provisions

1.1. This AML / KYT / KYC Policy (hereinafter the Policy) is an integral part of the Exchange Rules of the Brothers Exchange service and sets out the procedure for AML, KYT and KYC checks. Terms are used in the meanings defined in the Exchange Rules.

1.2. The Policy is aimed at identifying transactions related to the financing of terrorism, money laundering and other unlawful activity. The legalization of proceeds obtained by criminal means is the concealment of the illegal source of funds by converting them into money or investments that appear legitimate.

1.3. The User confirms their consent to the Policy when creating an order by ticking the corresponding mandatory box in the form.

2. General Requirements for Orders

2.1. The sender and the recipient of funds under an order must be one and the same person — the User who placed the order. Transfers in favor of third parties are prohibited.

2.2. The User's data specified in the order must be current and accurate.

2.3. Creating orders through anonymous proxy servers and other anonymizing connections to the Internet is prohibited.

3. Service Restrictions

3.1. The Service does not serve:

persons and entities included in the sanctions lists of the UN, the European Union or OFAC;
residents of high-risk jurisdictions subject to a FATF call for action: the DPRK, Iran and Myanmar.

3.2. The Service does not accept funds linked to darknet markets, mixers, fraud, ransomware, stolen funds, sanctioned services or gambling (online casinos, bookmakers and other gambling services).

4. KYT: Screening of Incoming Transactions

4.1. Every incoming cryptocurrency transaction is screened upon receipt through the AmlBot service. For the screening, AmlBot receives only wallet addresses and transaction hashes.

4.2. The order is put on hold if the screening shows that:

the overall risk level of the transaction exceeds 60%;
the share of funds from high-risk categories (Dark Market, Dark Service, Illegal Service, Sanctions, etc.) exceeds 15%;
a link to the funds referred to in clause 3.2 has been identified.

4.3. The Service notifies the User of the hold at the email address specified in the order within 24 hours of the hold, stating the reason for the hold and the list of information requested.

5. KYC: Identity Verification

5.1. By default, the Service does not verify the User's identity. Identity verification may be requested only in the following cases:

the screening under Section 4 has indicated an elevated risk and the order has been put on hold;
applicable law requires verification.

5.2. In these cases, the Service requests only what is necessary to assess the identified risk or to comply with the requirement of the law, from the following list:

a good-quality photograph of an identity document (passport or national ID card), showing all sides;
a photograph of the User holding this document;
information and documents on the source of funds: employment status and sources of income; where the funds came from (the deposit and withdrawal history on the platform from which they were sent); the purpose of receiving the funds; and, if the User received the funds from a third party, confirmation of this (correspondence, documents).

5.3. Bank cards are not verified, including by card photos or video verification: the Service does not accept payments from bank cards and does not make payouts to them.

6. Time Limits of the Check

6.1. The User provides the requested information within 30 days from the request.

6.2. The Service reviews the information within no more than 5 business days from the moment it has been received in full.

6.3. Throughout the check, the Service informs the User of its progress at least once every 3 days.

6.4. The User's funds are held only within the time limits set out in clauses 6.1 and 6.2. Funds may be held beyond these time limits only on the basis of an official order of an authorized state body.

7. Outcome of the Check and Refund of Funds

7.1. The risk is not confirmed — the order is executed. Execution at a rate different from the order rate is possible only with the User's explicit consent in accordance with clauses 5.4–5.6 of the Exchange Rules; if no consent is given, the funds are returned.

7.2. The risk is confirmed, a link to the funds referred to in clause 3.2 has been identified, or it has been established that the User is one of the persons referred to in clause 3.1 — the Service refuses to execute the order, and the funds are returned to the User.

7.3. The User has not provided the information within the time limit set out in clause 6.1 — the funds are returned to the address from which they were received.

7.4. An official order of an authorized state body has been received — the funds are held or transferred in accordance with that order.

7.5. In the event of a refund, the User receives the entire amount less only the actual network fee for the refund transfer. No other deductions, including a percentage of the amount, are applied. The User's funds are not appropriated by the Service.

7.6. The refund is made to the address from which the funds were received or, at the User's request, to another address of the User confirmed in accordance with Section 10 of the Exchange Rules: following the review — within the time limit set out in clause 6.2; if the information has not been provided — upon expiry of the time limit set out in clause 6.1.

7.7. If signs of money laundering are identified, the Service may refuse to execute the User's subsequent orders and may suspend or terminate the User's account on the website (if one has been created). Funds under orders already paid are paid out or returned in accordance with this section.

8. Screening of Outgoing Payouts

8.1. The Service pays out cryptocurrency only from addresses that are not classified as high-risk in the databases of AML analyzers, and guarantees the quality and legitimacy of the assets paid out in accordance with Section 8 of the Exchange Rules.

9. Interaction with State Authorities

9.1. Information about the User and the User's transactions is provided to authorized state bodies exclusively upon their official request in the manner established by applicable law.

10. Storage of Information and Documents

10.1. Documents and information obtained during checks are processed and stored in accordance with Section 15 of the Exchange Rules: data is transmitted over a secure connection (TLS), and only authorized employees of the Service have access to it.

11. Holding, Receiving and Paying Out Funds

11.1. Users' cryptocurrency is received to the Service's own non-custodial wallets, to which only the Service has access, and is paid out from the Service's own non-custodial wallets.

11.2. Exchanges and other custodial services are not used to receive, hold or pay out Users' funds.

11.3. Payment gateways, processing services and P2P platforms are not used for settlements with Users (clause 3.3 of the Exchange Rules). Bank cards and bank accounts are not used in exchanges (clause 5.3 of the Policy).

11.4. If the Service starts using an exchange or another custodial service to receive, hold or pay out Users' funds, it will list it in this Section before starting to use it. The edition date is shown at the beginning of the Policy.