AML Policy of the WM.Money Service

1. General Provisions

1.1. The WM.Money service adheres to Anti-Money Laundering (AML) principles and reserves the right to suspend the processing of financial transactions in cases where the AML check of a transaction sent by the client shows an increased level of risk.

1.2. As part of AML control, each cryptocurrency transaction is analyzed using specialized blockchain analytics tools. Transaction indicators must not exceed 65% risk, while the critical content of certain categories has the following indicators:

• Dark Service and Dark Market — 25%
• Mixer and Gambling — 25%
• Exchange Fraudulent, Scam, Illegal Service, Stolen and Ransom — 2.5%

High-risk sources may include transactions associated with such categories as Darknet Market, Dark Service, Mixer, Gambling Service, Fraudulent Exchange, Scam, Illegal Service, Stolen Funds, Ransomware, Sanctions, and other sources that analytical systems may classify as high-risk.

1.3. In the event that the specified risk indicators are exceeded, the service reserves the right to suspend the processing of the request and initiate additional verification in accordance with this AML Policy.

2. Additional User Verification

2.1. In certain cases, if additional transaction analysis is required, the service may request additional information or documents from the user.

2.2. As part of additional verification, the service may request:

• A photo of one of the documents (passport, ID card, or driver’s license)
• A selfie with this document and a sheet of paper on which the current date and signature are handwritten
• Information about the source of funds
• Additional details about the transaction

2.3. The service also reserves the right to request answers to clarifying questions regarding the transaction, including:

1. Through which platform were the funds received? Please provide screenshots of the withdrawal history and links to the transactions on the blockchain.
2. For what service were the funds received?
3. Transaction amount, date, and time of execution.
4. Sender’s contact person and screenshots of the correspondence confirming the sending of funds.

2.4. The list of requested data is determined individually depending on the results of the AML analysis and the circumstances of the specific transaction.

3. Restrictions and Liability

3.1. The service does not provide analysis of future transactions and does not answer questions regarding possible risks of exchange or conversion of funds.

3.2. If there are doubts about the cleanliness of cryptocurrency, the user may independently check the level of risk before paying for the request via the AML bot available on the service’s website.

3.3. The results of an independent check are for informational purposes only and do not отменяют the mandatory AML analysis carried out by the service after funds are received for the request.

4. AML Checks

4.1. AML checks are carried out for all cryptocurrency transactions.

4.2. In the event of receipt of funds with an increased level of risk, the processing of the request may be temporarily suspended for additional verification.

4.3. The service does not accept payments from sanctioned exchanges and platforms:

(the list may be supplemented by the service administration)

4.4. The service also does not accept funds from platforms: Capitalst, Rapira, Payeer, as well as from cryptocurrency casinos: Primedice, Stake, 1xBit.

5. Blocking of identical coins

5.1. If blocking occurred during the exchange of identical coins within the same network (for example, USDT TRC20 to USDT TRC20) only due to a high-risk transaction or suspicion of money laundering — verification may take longer.

5.2. The client performs the exchange at their own discretion and under their own responsibility.

6. Refund after AML check

6.1. If an increased level of risk is identified based on the AML analysis results, the service may decide to cancel the processing of the request.

6.2. After the AML check is completed, the funds are returned to the user without any additional deductions by the service — only the network fee is charged upon the refund.

6.3. The refund is made to the address or details from which the original transaction was made.

6.4. AML block — the final status is provided within 24 hours, refund processing may take up to 3 business days

6.5. The service does not withhold users’ funds without grounds and does not confiscate them.

7. Regulations for Processing Refunds and Related Operations

7.1 Refunds for payments without Tag/Memo — up to 3 business days from the moment the refund wallet is received.

7.2 Refunds for payments made in an unsupported currency/network — up to 7 business days.

7.3 Crediting payments returned to our hot wallet — up to 7 business days.

8. Refusal to undergo additional KYC / SoF verification

8.1. If the user refuses to provide additional information, documents, or materials requested by the service as part of AML control, the processing of the relevant request may be terminated.

8.2. In such a case, the received funds are subject to return to the sender to the address or details from which the transaction was made.

8.3. The refund is issued in full, with only the network fee deducted. No additional penalty or operational fees are applied by the service.

8.4. In most cases, the refund is made within 24 hours after the decision to terminate the processing of the request is made.

8.5. In rare cases, only mandatory blockchain network or payment system fees may be deducted during the refund, if such fees apply. In certain situations, the refund period may be extended and amount to up to 10 business days due to additional checks, особенностями работы блокчейн-сетей, as well as the requirements of payment systems or counterparties.

8.6. If there are relevant legal grounds, the service reserves the right to transfer information about the transaction and related circumstances to the competent authorities. The transfer of information and possible escalation of the case is carried out in accordance with applicable law.

9. Confidentiality and cooperation with authorities

9.1. All information of users regarding the request is confidential and is processed in accordance with the internal rules of the service and applicable legal requirements.

9.2. If there are grounds provided by law, the service may interact with competent authorities and provide the necessary information within the framework of official requests.

10. Prohibited countries

Afghanistan, Algeria, Bahamas, Bangladesh, Belarus, Bolivia, Burundi, Central African Republic, Congo, Congo (DR), Cuba, Ecuador, Ghana, Iran, Iraq, Lebanon, Libya, Mali, Mongolia, Morocco, Myanmar, Nepal, Pakistan, Palestine, Qatar, Russian Federation, Somalia, South Sudan, Sudan, Syrian Arab Republic, Trinidad and Tobago, United Arab Emirates, USA, Venezuela, Western Sahara, Yemen, Zimbabwe