General provisions

To prevent illegal transactions, the Service sets certain requirements for all Applications created by the User:

1. The sender and recipient of the Payment under the Application must be the same person. When using the Service, transfers to third parties are strictly prohibited.
2. All contact details entered by the User in the Request, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely accurate.
3. It is strictly prohibited for the User to create Requests using anonymous proxy servers or any other anonymous connections to the Internet.

This policy for combating the legalization of funds obtained by criminal means (hereinafter referred to as the “AML Policy”) describes the procedures and mechanisms used by the StoreBucks Service to counteract the legalization of funds. The StoreBucks Service adheres to the following rules:

• not to enter into business relationships with known criminals and/or terrorists;
• not to process transactions that are the result of known criminal and/or terrorist activity;
• not to facilitate any transactions related to known criminal and/or terrorist activity;
• has the right to restrict or prohibit the use of all or part of the services for citizens of countries such as Afghanistan, Bosnia and Herzegovina, the United States, the Democratic People’s Republic of Korea, the Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, Lao People’s Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine.
• Verification procedures

The StoreBucks service establishes its own verification procedures within the framework of anti-money laundering standards — the “Know Your Customer” (KYC) policy.

1. Users of the StoreBucks service undergo a verification procedure (providing a government-issued identification document: passport or ID card). StoreBucks reserves the right to collect Users’ identification information for the purposes of implementing the AML Policy. This information is processed and stored in strict accordance with StoreBucks’ Privacy Policy and Personal Data Processing Policy.
2. The StoreBucks service may also request a second document to identify the User: a bank statement or utility bill no older than 3 months, indicating the User’s full name and actual place of residence. The service also has the right to request photo/video verification of the customer if there are suspicions about the accuracy of the information provided.
3. The StoreBucks service verifies the authenticity of the documents and information provided by Users and reserves the right to obtain additional information about Users who have been identified as dangerous or suspicious.

If the User’s identification information has been changed or their activity appears suspicious, the StoreBucks service has the right to request updated documents from the User, even if they have been verified in the past.

AML Policy Compliance Officer

The AML Policy Compliance Officer is a StoreBucks employee whose responsibilities inсlude ensuring compliance with the AML policy, namely:

1. collecting User identification information and transferring it to the responsible personal data processing agent;
2. creating and updating internal policies and procedures for writing, reviewing, submitting, and storing all reports required by existing laws and regulations;
3. monitoring transactions and analyzing any significant deviations from normal User activity;
4. implementing a records management systеm for storing and searching documents, files, forms, and logs;
5. regularly updating risk assessments.

The person responsible for compliance with the AML Policy has the right to interact with law enforcement agencies involved in the prevention of money laundering, terrorist financing, and other illegal activities.

Transaction monitoring

Monitoring User transactions and analyzing the data obtained is also a tool for assessing risk and detecting suspicious operations. If money laundering is suspected, StoreBucks monitors all transactions and reserves the right to:

• report suspicious operations to the relevant law enforcement agencies;
• request the User to provide any additional information and documents;
• suspend or terminate the User’s account.
• suspend the exchange and freeze assets until the circumstances are clarified.
• return funds to the user by canceling the exchange procedure, in accordance with the user agreement.
• Risk assessment

The above list is not exhaustive. The person responsible for compliance with the AML Policy monitors User transactions on a daily basis to determine whether they should be reported and considered suspicious.

In accordance with international requirements, StoreBucks applies a risk-based approach to combat money laundering and terrorist financing. Thus, measures to prevent money laundering and terrorist financing are commensurate with the identified risks.

To comply with international anti-money laundering (AML) and counter-financing of terrorism (CFT) standards, the service employs a comprehensive set of transaction analysis and control measures.

All transactions processed through the service are automatically verified using a risk score based on data from a specialized AML analyzer.

The Risk Score reflects the risk level of the origin of funds.
If the Risk Score exceeds the established threshold, the transaction may be:
• temporarily suspended;
• sent for additional verification;
• blocked until KYC/SoF procedures are completed.

The Risk Score threshold is determined by the service’s internal regulations and is subject to change without prior notice.

To analyze transactions, the service uses specialized AML systems and blockchain analytics tools (Chainalysis, Crystal, AMLBot, or similar solutions).

The results of these tools’ analysis are used to make decisions on whether to conduct, suspend, or reject transactions.

If an elevated risk is detected, the service reserves the right to request the user to complete the verification procedure (KYC — Know Your Customer, SoF — Source of Funds).

The user may be required to provide the following documents:
• Identity document (passport / ID card);
• Selfie with the document or video verification;
• Proof of address;
• Proof of source of funds (screenshots, statements, transaction history, etc.);
• Other documents at the request of the security service.

The verification procedure includes the following stages:
1. Automatic AML analysis of the transaction;
2. Manual verification by specialists, if necessary;
3. Request for documents from the user;
4. Analysis of the provided data and decision-making.

Approximate verification timeframes:
• Initial verification: from a few minutes to 24 hours;
• Extended verification (KYC/SoF): up to 3 business days;
• In some cases, the period may be extended if additional analysis is required.

If the user refuses verification or the legitimacy of the funds cannot be confirmed:
• The transaction may be declined;
• The funds may be returned to the sender minus the network fee and/or service costs.

Refund Timeframe:
• Typically 1 to 5 business days after the decision is made;
• In some cases, the timeframe may depend on network load and other factors.

Refunds are made exclusively to the original payment details.

The Service reserves the right to:
• suspend or reject transactions without explanation if there is a suspected violation of the AML policy;
• request additional information and documents;
• transfer information to competent authorities in cases required by law.