Русский1. General Provisions
Exwell provides crypto-to-crypto exchange services, adhering to the principles of privacy, transparency, and user autonomy. The service strives to ensure a secure environment for operations while simultaneously complying with international standards for anti-money laundering, countering the financing of terrorism, and sanction restrictions.
2. Operating Model and Privacy
Exwell is focused on minimizing the collection of users' personal data. Under standard conditions, operations can be carried out without undergoing identity verification (KYC) procedures. At the same time, the service applies internal compliance control mechanisms that allow for regulatory compliance without excessive interference with user privacy.
3. AML Transaction Monitoring
All transactions passing through Exwell are automatically analyzed using third-party blockchain analytics tools, including AMLBot, Crystal, and Elliptic. This verification assesses the origin of funds, transaction history, and matches against international databases and risk categories. Each transaction is assigned a Risk Score, used as part of a risk-based approach.
4. Risk-Based Approach
The decision to process a transaction depends on the identified risk level. Transactions with a Risk Score up to 70% are processed in the standard manner; Transactions with a Risk Score of 70% and above may be temporarily suspended for additional verification, including KYC and/or Source of Funds (SoF) confirmation. In addition to the numerical Risk Score, the service also considers extra risk labels, including links to stolen funds, fraud, ransomware, darknet resources, mixing services, sanctioned entities, and other high-risk sources.
5. Additional Verification
If a transaction is identified as potentially risky, Exwell reserves the right to initiate an enhanced review. Within such a review, the following actions may be taken: Manual transaction analysis by compliance specialists; Request for information regarding the source of funds (Source of Funds); Request to undergo the identity verification procedure (KYC). Until the verification is completed, the transaction and associated funds may remain temporarily suspended.
6. When KYC May Be Required
Exwell reserves the right to request a one-time KYC procedure in exceptional cases, including regulatory requirements, law enforcement requests, court orders, sanctions checks, and other circumstances indicating a need for additional user identification. In such cases, the user may be directed to a verified compliance partner to complete the identity verification procedure. The verification period typically takes up to 3 days. If the user refuses to undergo the requested verification, the operation may be canceled and funds returned, minus applicable network fees.
7. Processing of Personal Data
Exwell does not store KYC documents or other personal data of users on its own servers. Identification procedures are performed by third-party partners in accordance with applicable legal requirements, including GDPR and other international data protection standards.
8. Requested Materials
As part of an additional verification, the user may be required to provide documents and information necessary to complete the compliance procedure. For KYC, the following may be requested: A photo or scan of an identity document (passport, national ID, or driver’s license); A photo of the user holding the identity document. To confirm the source of funds (Source of Funds), the following may be requested: Screenshots or statements from the wallet from which the transaction was sent; Transaction history confirming the origin of funds; Screenshots of accounts from cryptocurrency exchanges or services through which the funds were received; An explanation of the source of funds. The service reserves the right to request additional materials if necessary to complete the check.
9. Verification Timelines
After receiving all necessary materials, the check typically takes up to 3 business days. Until the required information is received and the verification is completed, the transaction may remain temporarily suspended.
10. Refund Terms
Based on the verification results, the following outcomes are possible: Completion of the exchange operation if no violations are found; Return of funds to the sender if the operation cannot be performed or the user refuses the verification procedure; Return of funds to the rightful owner if the service receives an official request or mandatory order from competent law enforcement confirming the illegal origin of funds. In the event of a return, funds are sent to the appropriate address in accordance with the verification results and applicable legal requirements. If the return is made to the sender, funds are transferred to the sender's original address within 24 hours after the check is completed; only the network fee required for the blockchain transaction may be withheld.
11. Fund Retention Period
The retention period depends on the nature of the check and the circumstances of the specific case. In a standard check, funds may be held until the user provides all necessary information and the check is concluded. In certain cases, the retention period may be extended if required to comply with legislation or to execute official law enforcement requests.
12. Service Usage Restrictions
Exwell does not support or permit the use of the service for money laundering, terrorist financing, or other illegal activities. The service does not cooperate with individuals or organizations involved in fraud, sanctions violations, or other unlawful acts. User funds are not frozen except in cases expressly provided by law, court orders, or mandatory regulatory requirements.
13. For Victims of Theft
If you are a victim of cryptocurrency theft and suspect the funds were transferred through Exwell, you must contact support and provide a detailed description of the situation along with available blockchain evidence. Additionally, documents from law enforcement regarding the relevant case may be requested. Upon receiving an official legal request, Exwell may assist in tracking the transaction within its authority and applicable law. If the funds have already been exchanged, the service's actions may be limited to the destination currency and carried out solely based on an official legal request.
14. Final Provisions
Exwell strives to maintain a balance between user financial privacy and fulfilling regulatory obligations. Use of the service signifies the user's agreement with this KYC/AML Policy.