Anti-money laundering policy

Both international and local rules and legislation require that the MafinCash.com exchange service maintain effective internal procedures to prevent any illegal activity and take all necessary measures to do so.
The MafinCash.com service adheres to practices in the area of countering the legalization (laundering) of proceeds of crime and financing of terrorism (AML - Anti Money Laundering), as well as the "Know your Client" (KYC) policy.
AML/KYC policy covers the following issues:
- Verification procedures;
- Monitoring of transactions;
- Risk assessment.

1. Verification procedures
1.1. Confirmation of identity
The verification procedure on MafinCash.com requires that the User provide to the administration of the service genuine documents (for example, international passport, account statement, utility bill, etc.). For such purposes, MafinCash.com reserves the right to collect user identification information as part of its anti-money laundering and "know your customer" policies.
Also, MafinCash.com reserves the right to further check certain Users who have caused suspicion. The verification process includes providing documents confirming the identity of the User.
For individuals:
1) To verify your identity, you must provide one of the following documents:
- Civil passport;
- International passport;
-ID card.
2) To confirm the address, the User must provide one of the following documents:
- a statement from the bank, where the address of your actual residence is clearly visible;
- Utility bill, where the address of your actual residence is clearly visible;
- tax documents that clearly show the address of your actual residence;
- a document confirming the address of your actual residence, issued by the local authorities, where the address of your actual residence is clearly visible.
For corporate clients:
1) To verify your identity, you must provide one of the following documents:
- Director’s passport;
- Director’s international passport;
- Director ID;
2) To confirm the address, the User must provide one of the following documents:
- a statement from the bank, where the address of your actual residence is clearly visible;
- Utility bill, where the address of your actual residence is clearly visible;
- tax documents that clearly show the address of your actual residence;
- A document confirming the address of your actual residence, issued by local authorities, where the address of your actual residence is clearly visible.
3) To confirm that the User is an authorized representative of the organization, he must provide all the following documents:
- a document confirming the company’s legal address;
- the document on registration of legal entity;
- Order of appointment of the director;
- Scanned copy or photo of letter about the decision to work with MafinCash.com
4) Final beneficiary information:
- the civil passport of the final beneficiary;
- International passport of the final beneficiary;
- Final beneficiary ID;
— a document confirming the address of the final beneficiary. Final beneficiary, according to the Cypriot law, means a natural person who owns or controls the User’s Account and/or the natural person on whose behalf transactions are carried out.
1.2. Bank card verification
Users who want to exchange with a participating bank card must first verify it. Detailed instructions for the verification process can be found here.

2. Transaction monitoring
Users are verified not only by verifying their identity, but also by analyzing their transactions. Therefore, MafinCash.com relies on data analysis as a tool for risk assessment and detection of suspicious activity by users.
MafinCash.com provides data collection, filtering, record keeping, investigation management and reporting. With regard to the AML/KYC policy, MafinCash.com may monitor all transactions and reserves the right:
- to request any additional information and documents from the User in case of suspicious transactions;
- suspend or block the User’s account if MafinCash.com has reasonable grounds to suspect that the User is engaged in illegal activities.
The above list is not exhaustive, and transactions will be monitored on a daily basis to see if transactions should be considered suspicious.

3. Risk assessment
MafinCash.com, in accordance with international requirements, checks transactions for risk using AML services.
Therefore, a transaction can be rejected if the total risk exceeds 50%. The Service may also refuse to provide services if the risk exceeds 1.5% in the following categories:
- Dark Service - coins related to child abuse, terrorist financing or drug trafficking;
- Dark Market - coins that were used for shopping in the darknet;
- Scam - coins that were obtained by cheating their clients;
- Mixer - the coins were passed through a mixer to make their tracking difficult or impossible. Often used for money laundering;
- Illegal Service - coins related to illegal activities;
- Ransom - coins obtained through extortion or blackmail;
- Exchange Fraudulent - coins from the exchange related to fraud, illegal activities, or whose funds have been seized by the government;
- Stolen - stolen coins;
-Gambling - Coins associated with online casinos without a license.
In case the transaction is high risk, the User must undergo KYC verification to confirm identity.

4. Carrying out the exchange
The MafinCash.com service warns users against attempting to use MafinCash.com to legalize money obtained by criminal means, financing terrorism, fraud of any kind, as well as from using the service to purchase prohibited goods and services.
In order to prevent illegal transactions, the Service sets certain requirements for all Requests created by the User:
4.1. The Sender and the Recipient of the Payment under the Application must be the same person. Using the services of the Service transfers to third parties are strictly prohibited.
4.2. The contact data provided by the User in the Application, as well as other personal data transmitted by the User to the Service must be accurate and up-to-date. At the request of the User, personal data may be deleted from the database of the Service within 3 years from the date of the last implemented Application by the User.
4.3. If there is a reasonable suspicion by the administration of the Service that the user is trying to use the services of the Service for money laundering or any other illegal transactions, the administration has the right:
- suspend the exchange transaction of the user;
- request identity documents from the user;
- request other information regarding payments;
4.4. All information provided by the client may be transferred to the supervisory authorities in the following cases:
- upon the request of law enforcement agencies;
- by the decision of courts of different instances;
- upon request of the Payment System administrations.
Personal data includes:
- surname, first name, patronymic;
- e-mail address;
- country of residence/citizenship; - details of the wallets used;
- mobile phone number;
- the data of the identity document;
- location address
4.5. Processing of personal data means recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), including cross-border, depersonalization, blocking, the deletion, destruction of personal data not falling under special categories for processing which requires the written consent of the User.
4.6. Processing of personal data is carried out for the purpose of fulfilling the Parties' obligations under the Agreement, registering the User on the Service Site, providing technical support to the User, submitting Orders, providing the Services, handling appeals and claims, sending to the User’s e-mail address messages of an informative and other nature.
4.7. The basis for granting the Service the right to process User data is the consent of the User. Consent is given in the form of clear active actions of the User, namely one or a combination of these actions: registration of the User on the Service Site and self-provision by the User of necessary data during such registration, filling in an electronic form through the Service’s website for the purpose of submitting an Application, making a payment for the Application and other active actions using the Services.

MafinCash.com reserves the right:
1) require the User to provide additional information disclosing the origin of the digital assets and/or confirmation that these assets were not obtained by criminal means;
2) to block the account and any transactions related to the User, to transmit to the controlling financial activities and/ or law enforcement authorities at the place of registration of the Service and, if necessary, at the address of registration of the Customer all available information and documents on the incident;
3) require from the User documents confirming identity, video verification, registration address, capacity to pay;
4) to return digital assets only to the details from which the transfer was made, after a full check by the security service of the Service, if it has been possible to verify the legal origin of the funds of the Client;
5) to deny the User withdrawal of funds on account of third parties without giving reasons;
6) hold the User’s funds until a full investigation of the incident has been completed;
7) to monitor the entire transaction chain in order to identify suspicious transactions;
8) to deny the Service to the User if the Service has a reasonable suspicion in the legality of origin of digital assets or in case it is impossible to trace the entire chain of movement of assets since their appearance, and keep funds in special accounts of the Service.

- Please note that transactions with exchanges that are under sanctions (for example CommEx, Garantex, Hydra market, Tornado cash, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io and others) with any Iranian exchanges (for example Nobitex.ir, arzpaya.com) will be held and frozen by AML.

- Please note that in accordance with our company's internal policy, transfers using the Rapira service are classified as risky and are subject to mandatory verification within the framework of AML procedures.

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