1. Introduction

      Xchangepro.net is owned and operated by BlueData OU registration number 14438771, with an operational address on the 3rd floor of Metro Plaza, Viru valjak 2, Tallinn, 10111, Estonia. BLueData OU is licensed and regulated by the Estonian Ministry of Economics, The Financial Intelligence Unit (FIU) to provide services of exchanging a virtual currency against a fiat currency license number FVR00146.

      Xchangepro.net Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Xchangepro.net being involved in any kind of illegal activity.

      Both international and local regulations require Xchangepro.net to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

      AML/KYC Policy covers the following matters:

      1. Verification procedures.
      2. Compliance Officer.
      3. Monitoring Transactions.
      4. Risk Assessment.

  2. Verification Procedures

      One of the international standards for preventing illegal activity is Know Your Customer (KYC) and Anti-Money Laundering (AML) verification procedures. Xchangepro.net follows and monitors those procedures carefully under the general international standards. Furthermore, Xchangepro.net follows the AML/KYC requirements setfourth by the license provider (Financial Inteligence Unit FUI, Ministry of Economics, Estonia). Xchangepro.net reserves the right to decline or approve a User's verification at its sole discretion. Furthermore, Xchangepro.net reserves the right to require and ask the User for any further documents needed in order to complete the verification procedures. A User will not be able to perform any exchange activities, sell or purcahse, or withdraw any Crypto currency or Fiat currency, prior to successfully completing the following verification procedure and verify the following:

      1. Proof of Identity (POI)
      2. Xchangepro.net will accept the following Government-Issued picture identification IN COLOR as a POI:
      3. (1) Passport
        (2)Drivers License (For some countries)
        (3)National ID card (For some countries)
      4. Any document must be valid and with at least 6 months to expiration.
      5. Xchangepro.net will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Xchangepro.net reserves the right to investigate certain Users who have been determined to be at high risk or suspicious.
      6. Xchangepro.net reserves the right to verify a User’s identity (POI) in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User) or deemed at high risk by Xchangepro.net at its sole discretion. In addition, Xchangepro.net reserves the right to request up-to-date documents from the Users, even though they have successfully completed an identity verification in the past.
      7. User’s identification information will be collected, stored, shared and protected strictly in accordance with the Xchangepro.net’s Privacy Policy and related regulations.
      8. Once the User’s identity has been verified, Xchangepro.net is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
    1. Proof of Payment (POP)
      1. Xchangepro.net will verify any payment method used to fund an account with Fiat currencies. The User must provide a clear image or scan of the credit/debit/prepaid card used to fund the account. Images of both the back and front sides of the card must be provided.
      2. **Please note that for security and compalince only the last 4 digits of the card will need to be visible.
    2. Proof of Address (POA)
      1. Xchangepro.net will accept the following documents IN COLOR as a form of a POA:
      2. Utility Bill - Must be no older than 3 months. POA must clearly show the User's full name and full address. The address in the POA must match the address entered by the client at the time of the account opening. In the case that a User's residential address has changed from the original address provided, a new POA must be provided. The new POA will need to be approved once again by Xchangepro.net's compliance team in order to allow full site functionality.
        Acceptable POA:
        Gas/Water/Cable/Landline phone bill.
        Please note that cellphone bills will NOT be accepted as a valid form of POA.

  3. Compliance Officer

      The Compliance Officer is the person, duly authorized by Xchangepro.net, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Xchangepro.net’s anti-money laundering and counter-terrorist financing, including but not limited to:

      1. a. Collecting Users’ identification information. b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. c. Monitoring transactions and investigating any significant deviations from normal activity. d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. e. Updating risk assessment regularly. f. Providing law enforcement with information as required under the applicable laws and regulations.

      The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

      BlueData's compliance officer with regards to AML/compliance policies enforcement is Mr. Ken Kovask.
      Mr. Kovask is available at [email protected] or via phone at +372 668 0324

  4. Monitoring Transactions

      The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Xchangepro.net relies on data analysis as a risk-assessment and suspicion detection tool. Xchangepro.net performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

    1. Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
    2. Case and document management.
    3. With regard to the AML/KYC Policy, Xchangepro.net will monitor all transactions and it reserves the right to:

      ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;

      request the User to provide any additional information and documents in case of suspicious transactions;

      suspend or terminate User’s Account when Xchangepro.net has reasonably suspicion that such User engaged in illegal activity.

      The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

  5. Risk Assesment

      Xchangepro.net, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Xchangepro.net is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

  6. Nominated Officer

      BlueData's Nominated officer with regards to AML/compliance policies enforcement is Mr. Ken Kovask.
      Mr. Kovask is available at [email protected] or via phone at +372 668 0324