BAKSMANY AML/CFT AND FINANCIAL CONTROL POLICY

This document defines Baksmany"s operating principles in the areas of anti-money laundering (AML), combating the financing of terrorism (CFT), and Know Your Customer (KYC) compliance. The primary goal of this policy is to minimize the risks of the platform"s involvement in illegal transactions, protect the service"s reputation, and ensure the trust of regulators and users. The Service"s operations are based on FATF recommendations and the laws of the countries where it operates.

1. Identification of users

To access platform functionality beyond established limits, all clients are required to undergo verification. Baksmany uses third-party KYC providers to verify their data. The identity verification process is divided into two levels, which determine withdrawal limits:

Level 1 - Basic

At the basic level, standard user verification is performed. The following data is subject to verification:

• email address;
• user identity (identity document);
• residential address.

This level is applied to individual banking areas and standard operations not associated with increased risks.

Level 2 - Advanced

The extended verification level is applied in cases of increased risk or when the user has a high AML status.

As part of the extended verification, the following may be requested:

• email address;
• user identity verification;
• proof of residential address;
• confirmation of the origin of the source of funds (Source of Funds).

The decision to conduct an extended check and request additional documents is made by the service on an individual basis, based on the specific situation and risk assessment.

Required documents:

To pass verification, the client must provide information in Latin.

1. Proof of identity: A valid document with a photo, full name, date of birth, and serial number. Accepted documents include a domestic passport, international passport, or driver"s license.
2. Proof of Address: Documentation proving residence at the current address for the past three months. Acceptable documents include: a certified lease agreement, bank statement, utility bills, tax returns, or other official documents showing the address.
3. Photo verification: A selfie of the client holding a piece of paper with “Baksmany” and the current date written on it.

Confirmation of source of funds

As part of the enhanced verification process, the user may be required to provide documents confirming the legitimate origin of the funds. These documents may include, but are not limited to, the following:

1. Labor and business income: contracts, certificates, declarations, individual entrepreneur reports.
2. Banking transactions: statements of credits.
3. Investments and assets: dividends, purchase and sale agreements.
4. Gratuitous receipts: inheritance, donation.

The Service reserves the right to request additional documents or information depending on the specific situation and risk assessment.

Verification deadlines:

*Standard document verification: 1–24 hours.

*Enhanced Determination (EDD): 24–72 hours.

The Company reserves the right to request updated documents at any time, especially if suspicious activity is detected, even if verification has been completed previously.

2. Transaction Security and Monitoring (KYT)

The service guarantees the legitimacy of the assets transferred. All cryptocurrency payments comply with the requirements of international regulators (FATF, OFAC) and are processed through:

* Unique one-time addresses.

* Low-risk addresses according to AML analyzer databases.

* Addresses of licensed platforms.

Monitoring system:

Baksmany uses automated and manual analysis methods (including AMLBot) to evaluate each transaction. This screening includes searching for links to sanctions lists, the darknet, and fraud, as well as identifying mixers and suspicious patterns (smurfing, abnormal volumes, transfers to new wallets).

Risk scoring model:

Each transaction is assigned a risk score:

* Low: Score up to 62%.

* Medium: Rating from 62% to 70%.

* High: Score from 70% to 75%.

Transactions with a High Risk status may be blocked and transferred to an AML officer for manual review. We recommend that you conduct checks yourself before sending a transaction to the exchange service and make sure that the address does not contain a risk. Our checks are carried out based on AML bot processing. A preliminary address check can be performed through bestchange.com/report.

3. Risk management and restrictions

Client categorization:

Depending on the risk profile, different due diligence measures are applied to clients:

1. Low Risk: Standard Check (CDD).
2. Medium risk: Enhanced monitoring and re-checking every 2 years.
3. High Risk: Implementation of Enhanced Due Diligence (EDD) procedures, including source of funds inquiry, in-depth transaction history review, and annual KYC updates.

Automatic classification as high risk:

* Politically exposed persons (PEP) and their close relatives.

* Residents of countries from the FATF High-Risk Jurisdictions list.

* Clients with an annual turnover of over $100,000.

Handling suspicious transactions:

If signs of illegal activity are detected, the Service has the right to:

* Suspend the transaction and block the account until the investigation is completed.

* Generate an internal report (SAR/STR) and notify the competent authorities (Rosfinmonitoring, FinCEN, EU FIU, etc.).

* Deny service if the client refuses verification.

Blocking fees:

If funds are blocked for AML reasons, the refund fee is up to 5% of the amount, but no more than $100. Refunds are not possible if the assets are deemed criminally related or are subject to seizure by authorities. For bona fide clients whose funds are not linked to money laundering, the fee is limited to network fees.

Affiliate network:

Baksmany does not partner with platforms in jurisdictions with weak AML regulations. All counterparties undergo due diligence and must be licensed and comply with international standards.

4. Internal control and data protection

Organization of control:

* An AML officer has been appointed responsible for the policy (contact: [email protected]).

* Staff undergo mandatory AML/CTF training at least once a year.

* Internal audits are carried out quarterly, with the involvement of independent consultants if necessary.

All cryptocurrency transfers to clients comply with AML standards of global regulators, including FATF and OFAC. Payments from the Service are processed through:

• unique (one-time) crypto wallets;
• low-risk addresses according to AML analyzers and blockchain explorers;
• wallets of licensed crypto platforms.

Storage of information:

Personal and transaction data is encrypted and stored on secure servers in jurisdictions that comply with GDPR and MiCA standards. Access is restricted to authorized employees. Data retention is for at least three years after the termination of the client relationship (unless otherwise provided by law).

Final Provisions:

This Policy is part of the User Agreement. Baksmany reserves the right to make changes unilaterally by notifying users on the website. By using the service, the client automatically accepts the terms of this AML Policy.

5. Prohibited Jurisdictions and Contacts

Geographic restrictions:

Users from countries and territories blacklisted by the FATF, OFAC, EU, UN, and the following jurisdictions are not permitted to use the Service:

* Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma).

* Any territories added to the specified lists as of the date of the operation.

Contact information:

To report suspicious activity and contact the responsible AML officer, please use the address:

[email protected]

© Baksmany, 2026.