AML Policy Easyglobal.org

Contents

• 1. General Provisions
• 2. Transaction Monitoring and Control
• 3. AML Verification and Risk Assessment Criteria
• 4. Actions in Case of High Risk Detection
• 5. Verification of Order Information
• 6. Refunds for High-Risk Transactions
• 7. Refusal of Service
• 8. Refusal to Provide Services
• 9. Dispute Resolution
• 10. Storage and Protection of Information
• 11. Prohibited Jurisdictions

1. General Provisions

This AML Policy regulates the activities of the Easyglobal.org exchange service in the field of anti-money laundering and prevention of the use of the service for legalization of illegally obtained funds. The Policy is developed in accordance with the recommendations of FATF (Financial Action Task Force on Money Laundering).

2. Transaction Monitoring and Control

In accordance with this AML Policy, the exchange service performs analysis, monitoring, and control of transactions (AML verification) carried out through the Easyglobal.org service.

3. AML Verification and Risk Assessment Criteria

The exchange service conducts AML verification of all client transactions using specialized blockchain analytics and AML monitoring services.

The service performs automatic analysis of each transaction using AML risk scoring (Risk Score). The assessment is based on the source of funds, wallet history, associated services, risk categories, and other blockchain analytics parameters.

Risk assessment criteria:

Risk Score is a dynamic indicator and may change over time depending on updates to blockchain analytics data and monitoring sources.

Important: an order may be automatically rejected if:

• the total transaction risk level exceeds 60%;
• the risk indicator for a specific category exceeds the allowed threshold;
• a connection with prohibited services, platforms, or sanctioned addresses is detected.

3.1. Maximum Allowed Risk Values by Category

During AML verification, the service also takes into account separate risk labels assigned to transactions and cryptocurrency addresses by blockchain analytics systems.

For certain categories, the service establishes maximum allowed risk percentages. If the limits specified below are exceeded, the transaction may be automatically rejected, blocked, or suspended for additional verification.

Categories with a value of 0% are fully prohibited. Even a minimal connection between a transaction and such categories may result in automatic rejection of the order.

Categories with a value below 100% have maximum allowed risk limits established by the service. Exceeding these limits may result in automatic blocking, refusal of processing, or additional AML verification.

Categories with a value of 100% are permitted by the service and are not considered an independent reason for blocking or refusing transaction processing.

Transactions associated with the following platforms and services are prohibited and subject to automatic rejection:

Black Sprut, BTC-e, ChipMixer, DuelBits, FreeBitcoin, Hydra, NVSPC, Roobet, Tornado Cash, WEX Exchange, Yolo Group, Garantex, CommEX, Blender.io, Lazarus Group, Genesis Market, Shinbad.io, Primedice, Wasabi Wallet, Bitzlato, Bitpapa.com, Trocador.app, Cryptomus, Nobitex.ir, 1xBit, 1xBet and all affiliated entities, Aifory.pro, SkyCrypto.net, FlashObmen.com, CoinBlinker.com, Vexel, Fun Pay, WebMoney, FreeKassa.ru, Yobit, exmo.com, exmo.me, CryptoCloud, Cripta, BitBits, Nix Money, Bixter, Payeer.com, Rapira.net, Peer.com, Capitalist.net, Grinex.io, Meer.kg, Terminal.cash, 60cek.net, HD-Change.com, Metka.cc, Alfabit.org, Weiss.bet, xRocket.tg, Heleket.com, Arvix.pro (ABCeX.io), ProstoCash, CoinStart, Kassa.cc, OFSI Huobi Global S.A. (HTX.com), MEGA Darknet Market, OMG!OMG!, Darknetone, DuckDice, Gandhiji.io, Stake, DoubleWay, NetEx24.net, Capitalist, Rapira, Sinbad.io and other similar services and platforms posing a heightened AML risk.

The user may also independently perform a preliminary AML check of a cryptocurrency address or transaction using the dedicated tool available on the service website: AML Checker.

4. Actions in Case of High Risk Detection

If a detailed transaction analysis reveals high-risk indicators, the service reserves the right to:

1. Suspend order processing and temporarily hold the client’s funds until completion of the AML verification.
2. Refuse to process the transaction if the permitted risk level is exceeded.
3. Return funds to the client without KYC verification in accordance with this AML Policy.
4. Restrict or completely terminate further servicing of the client.

5. Verification of Order Information

All transactions are analyzed based on the information specified in the order. Refunds are made exclusively to the payment details specified by the client in the order or via the official service email address: [email protected].

6. Refunds for High-Risk Transactions

Refunds are made to the client’s original wallet or to other payment details provided by the client and technically available for processing, in accordance with this AML Policy.

6.1. General Refund Conditions

• AML hold: up to 24 hours to obtain the final verification status and up to 3 business days to complete the refund.
• Payment without Memo/Tag: refunds are processed within up to 3 business days after the client provides a valid refund wallet address.
• Unsupported currency or network: refunds may take up to 7 business days.
• Refund to a hot wallet: crediting and processing of funds may take up to 7 business days.

6.2. Refunds in Case of High AML Risk

• If a transaction is identified as high-risk, the funds may be returned to the client without KYC verification unless otherwise required by applicable law.
• Refund timeframes for high-risk transactions correspond to the periods specified in section 6.1 of this Policy.
• Only the network fee required to process the transaction may be deducted during the refund. No additional service fees are charged.
• After processing a refund in high-risk cases, the service reserves the right to refuse further servicing of the client.

7. Refusal of Service

The exchange service reserves the right to refuse further servicing of a client if high-risk transaction indicators are detected or if the terms of this AML Policy are violated.

8. Refusal to Provide Services

The service reserves the right to refuse to provide exchange services at any stage and without explanation of the reasons.

9. Dispute Resolution

Any disputes arising under these Rules shall be resolved through negotiations between the parties. If no agreement is reached, disputes shall be resolved in accordance with the laws of the country where the Defendant is located.

10. Storage and Protection of Information

Information regarding exchange operations is stored solely for the purpose of resolving possible disputes and ensuring service security. Access to such information is granted only to authorized employees of Easyglobal.org. The service guarantees confidentiality, protection, and non-disclosure of user data in accordance with internal security policies and applicable law.

11. Prohibited Jurisdictions

The following countries are prohibited from using the Easyglobal.org service: United States, Afghanistan, Somalia, South Sudan, Democratic Republic of the Congo, Trinidad and Tobago, Uganda, Vanuatu, Iran, Russian Federation, Republic of Belarus.