AML & KYC Policy

1. General provisions

his Policy governs the measures applied by the xbit.money service (hereinafter, the “Service”) to counter money laundering (AML) and to conduct user identification procedures (KYC).

By using the Service, the User confirms that they:

  • use funds of lawful origin;
  • act on their own behalf;
  • accept the terms of this Policy.

The Service adheres to a zero‑tolerance policy toward operations related to illegal activities and reserves the right to refuse service without explanation if signs of such operations are detected.

2. Usage restrictions

It is prohibited to use the Service for:

  • legalization of illicit proceeds;
  • financing unlawful activities;
  • conducting operations using funds of dubious origin.

It is prohibited to use the Service via anonymous networks, proxy servers, VPNs, or other technologies that hide the User’s real IP address.

3. Transaction checks and risk assessment

All incoming transactions may be subject to AML checks after they are received by the Service.

The analysis is carried out using:

  • the AlfaBit blockchain analytics system available at alfabit.org;
  • automated scoring algorithms;
  • internal compliance procedures.
3.1 Risk levels

Based on the analysis and AML risk score, transactions may be classified as follows:

  • ​Low risk (up to 39%) – the operation is processed in standard mode.
  • Medium risk (40–69%) – additional verification may be required.
  • High risk (70–100%) – the operation may be suspended and sent for enhanced review, and funds may be blocked. Sending funds with such a risk level is not recommended.

Transactions are also classified as High risk if, according to the analysis, they are associated by more than 3% with:

  • ​Terrorism financing;
  • Sanctions;
  • Ransomware;
  • Participation in fraudulent schemes;
  • Possession of stolen assets.

The Service reserves the right to interpret the assessment results and make decisions based on them. The User can perform a preliminary risk assessment independently via bestchange.com/report.

4. Actions in case of detected risk

If a transaction is classified as medium or high risk, the Service may:​

  • suspend execution of the order;
  • request additional information from the User;
  • initiate a KYC procedure;
  • refuse to process the operation.
5. Review timeframes

The review period depends on the risk level and the completeness of the data provided.

Approximate timeframes:

  • standard review (low risk): up to 24 hours;
  • additional review (medium risk): from 1 to 3 business days;
  • enhanced review (high risk): up to 10 business days.
6. Identification (KYC)

The Service may request that the User complete a KYC procedure if there are grounds to do so.

The User may be required to provide:

  • an identity document;
  • proof of source of funds;
  • photo or video verification;
  • other documents upon request.
7. Refusal to undergo verification

If the User refuses to undergo verification, the Service may:

  • refuse to process the operation;
  • suspend the order;
  • restrict access to the Service.
8. Funds blocking

Funds may be temporarily held:

  • for the duration of the review;
  • if signs of high risk are detected;
  • where interaction with competent authorities is required.
9. Refunds

Refunds are processed after the review period has expired and, as a rule, are sent back to the original source of funds.

The maximum holding period is 10 business days, except where the funds are classified as high risk and the User refuses to undergo verification; in this case, data may be transferred to financial and law‑enforcement authorities, and the funds may remain blocked until the relevant investigation is completed.

9.1 Refund fees

The following may be deducted upon refund:

  • ​network fees (blockchain fees);
  • a fee of up to 5% of the transaction amount (not more than 100 USD equivalent) – only for high‑risk funds or if the User refuses to provide data for verification;
  • other actual expenses of the Service (not more than 5 USD equivalent).
10. Special conditions for high‑risk transactions

If the transaction risk exceeds 70%, the Service may:

  • fully refuse to execute the operation;
  • initiate a mandatory KYC procedure;
  • transmit information to competent authorities / financial intelligence units / law‑enforcement agencies and refuse a refund until completion of the investigation.

11. Jurisdictional restrictions

In accordance with the Final Rule of the Financial Crimes Enforcement Network (FinCEN) under Title 31 of the Code of Federal Regulations 1010.100(ff), which requires each foreign firm providing money services to appoint a U.S.‑resident agent for service of process under BSA requirements, Xbit.Money does not provide electronic currency exchange services to U.S. citizens or users residing in the United States.

The services provided by Xbit.Money may be prohibited by law in certain jurisdictions; you must independently and consciously refrain from using the Service if there are legal restrictions in your country.By accepting the terms of use of Xbit.Money’s services, you confirm that you are not a resident of such a jurisdiction, including but not limited to the United States of America.

List of jurisdictions whose residents are not served by Xbit.Money:

  • ​Afghanistan
  • Belize
  • Yemen
  • Canada
  • DPRK (North Korea)
  • Libya
  • Mauritania
  • Mali
  • Niger
  • Republic of the Congo
  • Democratic Republic of the Congo
  • Rwanda
  • Somalia
  • Sudan
  • Central African Republic
  • South Sudan
  • Iran
  • USA.
​12. User recommendations

Users are advised to:

  • use only verified sources of funds;
  • avoid interacting with high‑risk services;
  • keep in mind that cryptocurrency transactions are subject to analysis;
  • understand potential delays when the risk level is elevated;
  • conduct a preliminary check of their assets using one of the trusted services such as bestchange.com/report.
13. Information sharing

The Service may share information with:

  • analytical providers;
  • payment partners;
  • authorized authorities,

for the purpose of complying with legal and compliance requirements.

14. Service limitations

The Service may:

  • refuse service;
  • restrict access to functionality;
  • terminate interaction with the User,

if necessary to meet security requirements.

15. Policy changes

The Service may amend this Policy without prior notice.The current version is published on the website.

16. Final provisions

This Policy is mandatory for all users and applies to all operations conducted through the Service.


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