This Policy sets out the principles applied by Cryptosha for transaction analysis, risk management, AML/KYC procedures and, where necessary, Source of Funds (SoF) verification.
A request to complete KYC/SoF procedures or the temporary suspension of a transaction does not constitute an accusation of unlawful activity and does not in itself indicate that the funds are of unlawful origin.
Such measures are applied for risk management, fraud prevention, and transaction security purposes.
By creating and paying for an Order, the User confirms that they have reviewed this Policy and accept the possibility of an AML/KYC review under the terms set out below.
1.1. This Policy is applied for the purpose of identifying and reducing risks associated with the possible unlawful origin of funds, fraud, terrorism financing, and other high-risk categories of transactions.
1.2. Cryptosha applies a Risk-Based Approach (RBA), under which each transaction is assessed based on the combination of available risk factors.
1.3. Transactions sent to the Service may undergo automated AML screening and, where necessary, additional manual review.
1.4. Depending on the results of the analysis, a transaction may be processed in the ordinary course, referred for additional review, or temporarily suspended until the required information is obtained.
2.1. To analyze cryptocurrency transactions, Cryptosha uses specialized AML tools and monitoring systems, including GetBlock, as well as additional analytical and publicly available information sources where necessary.
2.2. During the analysis, a Risk Score may be generated as a comprehensive assessment of the transaction’s risk level.
The assessment may take into account:
- transaction history associated with the address;
- the apparent source of funds;
- connections with other addresses and counterparties;
- the presence of High-Risk indicators;
- connections with known high-risk categories;
- other technical and analytical parameters available to the monitoring systems used.
- below 60% — as a general rule, the transaction is processed without additional review where no other material risk factors are identified;
- from 60% to 74% — the transaction may be referred for additional internal analysis;
- 75% or higher — the transaction may be temporarily suspended for additional analysis and KYC/SoF procedures.
The Risk Score is one of the factors used in the assessment and is considered together with other available information.
A high Risk Score does not in itself constitute proof that the funds are of unlawful origin.
Additional review may also be conducted at a lower Risk Score if a material High-Risk indicator is identified, information concerning possible fraud is received, or other circumstances require additional analysis.
2.4. The analysis may inсlude checking a transaction for connections with high-risk categories, including:
- Terrorism Financing;
- Sanctions;
- Dark Market and Dark Services;
- Scam and Fraud;
- Ransomware;
- Stolen Coins;
- Mixer;
- Fraudulent Exchange;
- Illegal Service;
- Child Exploitation;
- Enforcement Action;
- other high-risk categories identified by the analytical systems used.
2.5. The Risk Score ranges specified above are the current reference thresholds used within the Service’s internal risk-management systеm. If the risk-assessment approach changes, the current version of this Policy will be published on the website.
3.1. A transaction may be referred for manual review where an increased Risk Score, High-Risk indicators, information concerning possible fraud, or other material risk factors are identified.
3.2. Additional analysis is carried out by an authorized member of staff using the results of AML systems and available information relating to the specific transaction.
3.3. Decisions are made based on the combined results of automated analysis, Risk Score, identified connections, and the circumstances of the specific transaction.
4.1. If additional information is required to complete a review, the User may be requested to complete an identity verification procedure or provide information concerning the source of funds.
- an identity document;
- a selfie or video verification with the identity document.
- a screenshot of the wallet or account from which the transaction was made;
- information concerning the relevant transaction;
- signing a message using the cryptocurrency address, where technically supported.
- confirmation of withdrawal from an exchange or another service;
- history of relevant transactions;
- information concerning the acquisition or receipt of the digital assets;
- other materials reasonably capable of establishing the source of funds.
4.2. The information requested is determined on a case-by-case basis, taking into account the nature of the transaction and the risk factors identified.
4.3. The Service seeks to request only the information necessary to review the specific transaction.
- bank card PIN codes;
- CVC/CVV codes;
- SMS or push-notification verification codes;
- passwords for banking applications;
- seed phrases;
- private keys;
- any other confidential information that provides access to your funds.
- standard review — up to 24 hours;
- additional analysis — up to 3 business days;
- complex cases — up to 7 business days.
5.1. These timeframes apply where the Service has received all information necessary to conduct the review.
5.2. If additional information is required from the User, the review period may be calculated from the time the required information is received.
5.3. These timeframes may be exceeded where the transaction is subject to an official request from a governmental or law-enforcement authority, an external restriction imposed by a bank, exchange, payment systеm, or another participant in the transaction, or where completion of the review depends on information from a third party.
6.1. If the exchange cannot be completed following a review, or the Service decides not to proceed with the transaction, the funds may be returned to the sender after the necessary review procedures have been completed.
6.2. Before processing a refund, the Service may request information necessary to verify the sender, establish ownership of the funds, and confirm a safe refund address or payment details.
6.3. A refund may be subject to deduction of actual expenses directly associated with returning the funds, including blockchain network fees, payment infrastructure fees, and other expenses relating to the specific transaction.
6.4. Such deductions do not constitute a penalty for undergoing an AML/KYC review and are not automatically charged at a fixed rate.
6.5. The User may request information from Support regarding the expenses taken into account when processing the refund.
6.6. Once the necessary reviews have been completed, the standard refund processing period is from 1 to 7 business days, provided that the refund is not subject to external restrictions or dependent on the actions of third parties.
7.1. Certain transactions may involve unique or one-time cryptocurrency addresses, as well as infrastructure provided by third-party services, payment platforms, or exchanges.
7.2. Such participants may apply their own transaction-analysis procedures, restrictions, and risk-management rules.
7.3. If a third-party participant suspends a transaction related to an Order for its own review, the Order processing time may be extended until the relevant procedure has been completed.
8.1. Before creating an Order, the User may independently conduct a preliminary AML check of an address or intended transaction using available third-party services.
8.2. The BestChange monitoring tools may also be used as an additional source of information.
8.3. The result of any third-party preliminary check is provided for informational purposes and does not guarantee an identical result from a subsequent analysis by Cryptosha or other participants involved in the transaction.
8.4. The User’s decision not to conduct a preliminary check does not constitute a violation, but it does not exclude the possibility of a subsequent AML/KYC review.
9.1. Cryptosha reviews official requests from competent governmental and law-enforcement authorities relating to specific transactions or Users.
9.2. Before providing information, the Service takes reasonable measures to verify the official nature of the request, its source, and the authority of the requesting party.
9.3. Information will not be provided solely on the basis of an informal request or an unverified claim that a person represents a governmental or law-enforcement authority.
9.4. The scope of information provided is limited to information available to the Service and relevant to the subject matter of the request.
10.1. Personal data and documents obtained as part of AML/KYC reviews are stored within protected server infrastructure used by the Service with restricted access.
10.2. Such data must not be stored on employees’ personal computers, removable media, or other local devices not intended for such storage.
10.3. Access is granted only to authorized persons to the extent necessary to conduct a review, process a transaction, or handle a disputed matter.
10.4. For information security purposes, Cryptosha does not publicly disclose detailed information regarding the physical location of its server infrastructure, its configuration, security mechanisms, or other technical parameters whose disclosure could increase the risk of unauthorized access or targeted attacks.
10.5. Information obtained is used for processing the relevant transaction, conducting AML/KYC reviews, preventing fraud, handling disputed matters, and processing duly issued official requests.
11.1. Personal data and documents obtained as part of AML/KYC reviews may be retained for up to 5 years from the User’s most recent transaction.
This period is an internal Cryptosha retention period used for reviewing previous transactions, potential claims, disputed situations, preventing repeated fraudulent activity, and processing official requests.
11.2. At the end of the retention period, the data shall be deleted or anonymized unless continued retention is required in connection with an unfinished transaction, an ongoing dispute, an incident investigation, or an official request under review.
12.1. If the User requires clarification regarding an AML/KYC review, transaction suspension, requested information, or refund, the User may contact Cryptosha Support.
12.2. To review the request, the User must provide the Order number and information sufficient to identify the relevant transaction.
12.3. Requests are reviewed individually, taking into account the results of the transaction analysis, materials provided by the User, and other circumstances relating to the specific transaction.
13.1. Cryptosha applies AML/KYC procedures as risk-management, fraud-prevention, and transaction-security measures.
13.2. Before creating an Order, the User may review this Policy, the User Agreement, and the terms applicable to the selected exchange direction and independently decide whether to use the Service.
13.3. Cryptosha may updаte this Policy where transaction-analysis methods, infrastructure, risk-management approaches, or security requirements change. The current version of the Policy is published on the website.
If the User would like to clarify the AML screening procedure, KYC/SoF requirements, or the specifics of a particular transaction, we recommend contacting Cryptosha Support before creating and paying for an Order.
