AML/KYC/KYT Policy

Publication and Effective Date: March 19, 2026

By using the Let'sPay Service (hereinafter referred to as the "Service") and/or creating an exchange request, the User confirms that they have read this AML/KYC/KYT Policy (hereinafter referred to as the "Policy") and agree to comply with its terms.

The Service adheres to practices and measures in the field of combating money laundering (AML - Anti-Money Laundering), counter-terrorist financing (CFT), sanctions evasion, fraud, and other illegal activities.

The purpose of these measures is to confirm that the Service takes seriously any attempts to use its platform for illegal purposes.

1. Terms and Definitions

AML (Anti-Money Laundering) — measures to prevent money laundering.
EDD (Enhanced Due Diligence) — enhanced verification applied in cases of increased/high risk.
KYC (Know Your Customer) — identification and verification of the User.
KYT (Know Your Transaction) — monitoring and analysis of transactions (including analysis of the source of funds).
Risk-Score — an assessment of the risk level of a transaction/address based on AML analytics data and other indicators.
SoF (Source of Funds) — confirmation of the origin of funds.
Sanctions Exposure — the presence of a direct or indirect link between a transaction/address/source of funds and sanctioned entities based on AML analytics and/or sanctions lists.

2. Blacklisted Platforms and Services

The Service does not cooperate with certain platforms and services. Before creating a request, the User must ensure that the funds being sent and/or the platform/service used to send the funds have no connection to the entities listed below.

Transactions associated with the following resources will be blocked as they will not pass AML checks:

1xbet and all related entities
1xBit
60cek.net
Aifory.pro
AlfaBit.org
bitpapa.com
Bitzlato
Black Sprut
Blender.io
BTC-e / FinCEN
capitalist.net
ChipMixer
CoinBlinker.com
CommEx
DuckDice
DuelBits
Exmo.com
Exmo.me
FlashObmen.com
FreeBitcoin
Gandhiji.io
Garantex
Genesis Market
grinex.io
hd-change.com
Heleket
Hydra
Lazarus Group (may operate periodically)
meer.kg
MEGA DARKNET MARKET
Metka.cc
netex24.net
nobitex.ir and any Iranian or similar platforms from sanctioned countries
NVSPC
OMG!OMG!
Payeer.com
Primedice
rapira.net
Roobet
Shinbad
SkyCrypto.net
Stake
terminal.cash
Tornado
Wasabi
WEX Exchange
Yolo Group
any cryptocurrency mixers
resources listed in publicly available sanctions lists

The list of prohibited platforms/services may be updated. The User is responsible for independently monitoring the current version of the Policy on the website.

3. AML/KYT Tools

To analyze transactions and sources of funds, the Service uses specialized blockchain analytics tools, including but not limited to:

AMLBot;
other AML/KYT services and analytical tools (depending on the network, asset, and verification scenario).

4. Risk-Score and Risk-Based Approach

The Service applies a risk-based approach: it assesses risks associated with the User, the transaction, and the source of funds, and depending on the result, applies standard or enhanced verification (KYC/SoF/EDD), suspends the operation, or refuses service.

To assess the risk of each cryptocurrency transaction/address, the Service uses a Risk-Score model formed based on blockchain analytics data, historical address connections, and other risk indicators.

Risk-Score Thresholds

Low Risk: 0–25% — standard processing.
Medium Risk: 25–50% — temporary suspension for additional verification may occur.
High Risk: 50% and above — the operation is temporarily blocked for AML control and KYC/SoF procedures (EDD if required).

Risk-Score may change over time (including due to updates in analytics data and cluster labeling).

5. Verification Stages

If Risk-Score thresholds are exceeded, AML triggers are activated, sanctions exposure is identified, or other high-risk indicators are detected, the Service may initiate a verification process that includes the following stages:

Temporary suspension of the operation — the exchange may be halted until verification is completed.
KYC/SoF request — the User will be asked to provide data and documents.
Analysis of submitted materials and transaction history — comparison with AML analytics results.
Decision — completion of the exchange or refusal and refund (if applicable).

The Service reserves the right not to disclose details of internal compliance assessments and/or reasons for specific triggers if necessary to comply with legal requirements, prevent abuse, or upon request of authorized authorities.

6. Requested Verification Materials (KYC/SoF)

Depending on the risk level and nature of the operation, the Service may request the following materials (non-exhaustive list):

Identity document (passport / ID card);
Selfie (including a selfie with the document) and/or photo/video verification (if required);
Proof of address (utility bill / bank statement / other document);
Proof of source of funds (SoF) — statements, screenshots, transaction links, platform transaction history, explanations of fund origin, etc.

Refusal to provide or provision of false/incomplete information is grounds for suspension of the operation, refusal of service, and/or refund (if applicable).

7. Estimated Verification Timeframes

The verification timeframe depends on the risk level and completeness of the provided materials.

Standard verification — from 1 to 7 business days from the moment all requested data and documents are received.
Enhanced verification (EDD/SoF) — from 30 to 60 calendar days. Enhanced verification is applied in cases of high risk, complex fund flow history, sanctions triggers, need for additional analysis, or other circumstances requiring extended compliance review.

Timeframes may be extended if the User fails to provide documents/explanations in a timely manner or if additional information is required to complete the analysis.

8. Terms and Timeframes for Refunds

If, based on AML/KYT verification results, the exchange cannot be completed, the Service reserves the right to initiate a refund to the sender, provided this is not prohibited by applicable law and does not contradict the requirements of competent authorities.

Refund conditions:

Return address/details — as a rule, refunds are made only to the original sender’s address/details (i.e., the address from which the funds were received by the Service), and not to third-party addresses.
No service fee is charged for refunds. Only the network fee required to process the refund transaction is deducted (the fee amount depends on the selected network).
Refund timeframes after a decision is made usually range from 1 to 5 business days, depending on the technical specifics of the blockchain network/payment infrastructure. Refunds are processed after completion of the relevant verification and receipt of all necessary data.

9. User Obligations, Self AML Check, and Risk Acceptance

Before creating an exchange request, the User must independently assess risks related to the origin of the funds being sent, including a preliminary check of the cryptocurrency address and/or transaction for compliance with AML requirements, as well as verifying the absence of connections with prohibited platforms/services specified in this Policy.

The Service strongly recommends that Users conduct independent AML checks of addresses and transactions in advance using publicly available specialized services, public AML tools, and blockchain explorers.

By creating an exchange request, the User confirms and agrees that:

they have independently assessed the acceptability and risks of using the funds being sent;
they have verified (and are responsible for verifying) the absence of connections with prohibited platforms/services specified in this Policy;
they understand that transactions may later be classified as high-risk or linked to illegitimate activities;
they accept the risk of possible suspension of the operation, AML/KYC/SoF/EDD verification, refusal of service, or refund in cases предусмотренных этой AML-политикой;
the Service is not responsible for consequences arising from the User’s use of funds with elevated AML risk if such risks could have been identified through prior independent checks.

Creating an exchange request is considered by the Service as explicit confirmation of the User’s agreement with this AML Policy, the verification procedures, and the allocation of risks associated with AML control.

10. Final Provisions

The Service reserves the right to update this Policy. The new version becomes effective upon publication on the website unless otherwise explicitly stated in the update text.

For questions related to AML/KYC/KYT and compliance checks, the User may contact support: info@letspay.me