AML

This policy defines how Cinus Exchange applies measures to combat money laundering, terrorism financing, fraud and other illegal activities.
The document applies to all users who carry out transactions through the service. Using Cinus Exchange means that the customer agrees to the procedures described herein, to the extent established by this policy and the main Rules of the service.
For the purposes of this policy, Cinus Exchange is referred to as the Service Provider, and the user of the service is referred to as the Customer.

The Service Provider complies with AML/KYC requirements and practices in order to mitigate risks related to illicit origin of funds, fraud and other unlawful activities.
The service does not engage with any natural or legal persons where there are suspicions that they are involved in money laundering, terrorism financing, or the use of funds obtained by illegal means.
Cinus Exchange does not provide separate advisory services for preliminary assessment of future transactions and does not assume any obligation to analyse, on behalf of the Customer, the risk level of an exchange or conversion that has not yet been carried out.
The responsibility for assessing the cleanliness of the Customer’s own assets lies with the Customer. If the user has doubts about the origin or risk level of funds, they must independently perform checks using public specialized resources or services that the Service Provider may indicate upon request.

During AML checks, the service may detect a link between a transaction or asset and the following high‑risk categories: Mixer, Sanctions, Ransom, Gambling, Scam, Malware, Dark Market, Dark Service, Stolen Coins, Terrorism Financing, Fraudulent Exchange, Illegal Service, Child Exploitation, Fraud Shop, Enforcement Action, High‑Risk Jurisdiction, Special Measures, Online Pharmacy.
These categories are used as internal risk assessment criteria within this policy.

For automatic AML checks of transactions, the Service Provider uses professional solutions CoinKyt, BitOK, as well as internal databases. All transactions are checked in accordance with international AML/CFT standards.
These systems are treated by the service as specialized verification providers, and their AML filters are used to analyse the risk level of customer transactions.
KYC verification is carried out in an automated manner using the third‑party service Didit. Processing of the Customer’s personal data within such verification is performed in accordance with the rules and terms of the verification service provider.

If AML analysis identifies a link to high‑risk assets of at least 0.1% or an overall transaction risk of at least 25%, the exchange operation is suspended.
In this situation, the Customer is requested to undergo KYC verification, since funds can only be refunded after successful completion of identity verification.

To complete verification, the Customer must provide valid and accurate identity documents. As a rule, a passport or driver’s license is used for this purpose.
If necessary, the Service Provider is entitled to request a selfie or selfie video to confirm the user’s physical presence and the match between their appearance and the submitted document.
Based on the verification results received from the verification service provider, the Service Provider may either refund the funds to the user or request additional documents and information.

Refund of assets that did not pass AML checks is only possible after successful completion of the KYC procedure.
If the Customer fails to pass KYC within 14 calendar days from the date the operation was blocked, the funds are transferred into full possession of the Service Provider without any right to refund.
If verification is successfully completed, the refund is made to the sender’s address within 24 hours or, at the Customer’s request, to another address within 10 days.
The refund amount is transferred in full, excluding the network fee required to send the funds.
Refund is not made if the relevant assets are subject to a request from competent authorities or other authorized bodies of any jurisdiction, since such assets may serve as material evidence in legal proceedings.

The Service Provider is not liable for the use of the service for the purposes of laundering criminal proceeds, terrorism financing or other illegal activities by users.
The service is also not liable for any damage caused by actions of third parties using the Service Provider’s services.