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Mchanger Platform Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy
Regulatory framework: National laws of the countries of presence and FATF recommendations
1. Introduction and strategic objectives
This document defines financial compliance standards for the Mchanger platform (hereinafter referred to as the "Service"). The primary objective of the Policy is to ensure operational transparency and compliance with legal requirements.
Key objectives of implementation:
* Elimination of the possibility of using the site for illegal transactions;
* Maintaining an impeccable business reputation and user trust;
* Full compliance with regulatory requirements of all jurisdictions in which the Service operates;
* Compliance with international standards (FATF) and local laws.
2. User Identification (KYC)
Know Your Customer (KYC) regulations
To ensure compliance with established limits and transaction security, access to the service"s advanced functionality is granted only after successful verification. Mchanger verifies client data using external KYC partner tools. The process is divided into two stages, the status of which determines withdrawal parameters:
Stage I: Standard Verification
Applies to standard transactions and certain banking areas not classified as high-risk. The user must provide:
- valid e-mail;
- a scanned copy of an identity document;
- proof of registration or residence address.
Stage II: Enhanced Due Diligence
This level is activated when a user profile meets high-risk criteria or requires special attention for anti-money laundering (AML) purposes. This stage may require:
- confirmation of contact information (e-mail);
- updating personal data;
- verification of residential address;
- documentary justification of the source of funds (SoF).
The Platform reserves the right to determine the need for an In-Depth Check on an individual basis, based on its internal risk assessment system.
Document requirements
To verify identity, scans or photos of one of the following documents are accepted:
* International passport;
* ID card;
* Internal passport of a citizen;
* Driver"s license.
To confirm your residential address (not older than 3 months), the following documents are suitable:
* Bank statement or certified lease agreement;
* Receipts for payment of utility bills/electricity;
* Tax return;
* Other official documents indicating the address.
Important conditions for registration:
* Data must be duplicated in Latin transliteration.
* Documents must be current and issued by government agencies.
* A selfie of the user holding a "Mchanger" sign and the current date is required.
Limitations and terms:
* The service does not serve residents of countries from blacklists (FATF, OFAC, EU, UN), including: Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma).
* Standard verification takes from 1 to 24 hours.
*Extended Date Determination (EDD) may take between 24 and 72 hours.
* In case of suspicious activity, re-verification is possible.
3. Monitoring of operations and risk assessment (KYT)
The service uses a hybrid analysis system (automated and manual) with the help of specialized providers (for example, AMLBot).
Transaction Analysis Criteria
The inspection is carried out in four main areas:
- Sanctions screening: identifying addresses associated with the darknet, fraud, or theft of funds.
- Anonymization: detection of traces of the use of mixers, tumblers, and private protocols.
- Suspicious patterns: fractional transfers (smurfing), abnormal volumes, transactions from high-risk regions.
- Risk scoring: assigning a transaction status (Low/Medium/High).
Risk management scale
The assessment is carried out according to the provider’s methodology:
* Low (Low risk): rate ≤ 62%.
* Medium (Medium risk): rate from 63% to 70%.
* High (High risk): rate from 70% to 75%.
Transactions with the “High Risk” status may be blocked automatically and transferred to an AML officer for manual review. We recommend that you conduct checks yourself before sending a transaction to the exchange service and make sure that the address does not contain a risk. Our verification is carried out based on AML bot processing.
For initial verification of addresses, the resource available is: https://www.bestchange.com/report/Procedure for confirming funding sources
To successfully complete the extended security verification, the User must provide proof of the legitimate origin of their funds. Acceptable supporting documents include:
- documents confirming the level of income (salary certificates);
- contracts with the employer;
- tax reporting;
- bank statements on cash flow;
- statements on receipt of income from investments or dividends;
- contracts for the purchase and sale of assets (transport, real estate, etc.);
- notarial documents on inheritance;
- agreements on gratuitous transfer of funds (donation);
- documentation of business income;
- other documents that can confirm the legality of the source of funds.
Depending on the individual situation and risk profile, the Service reserves the right to initiate a request for additional information not specified in this list.
Client categorization
Depending on the profile, different control measures are applied:
* Low risk: standard check (CDD), recheck as needed.
* Medium risk: enhanced monitoring, data updated every 2 years.
* High risk: Enhanced Due Diligence (EDD), Source of Funds (SoF) inquiry, annual KYC update.
Automatic high risk assignment:
* Politically exposed persons (PEP) and their relatives;
* Residents of countries from the FATF High-Risk Jurisdictions list;
* Users with an annual turnover of more than $100,000.
4. Platform Obligations and Data Security
Mchanger ensures the implementation of compliance procedures, threat monitoring, and information storage in accordance with the law.
Main guarantees of the Service:
- Compliance with KYC/KYT standards.
- Blocking suspicious transactions.
- Transfer of data to regulators (Rosfinmonitoring, FinCEN, EU FIU) if necessary.
- Storing transaction history and customer data for at least 5 years.
- Regular training of employees.
- Control of the legitimacy of the assets sent.
Requirements for outgoing payments:
* Use of unique one-time addresses.
* Sending funds only to low-risk wallets.
* Priority to addresses of licensed sites.
Information security and working with partners:
* All data is encrypted according to industry standards.
*Servers are located in GDPR and MiCA compliant jurisdictions.
*Only authorized employees have access to data.
* The platform does not cooperate with counterparties from zones with weak AML regulations; due diligence is conducted on partners.
5. Procedure for actions in case of violations
If signs of illegal activity are detected, the following action algorithm is followed:
- Immediate suspension of the operation.
- Account blocked until the end of the internal investigation.
- Preparation of internal report (SAR/STR).
- Notification of competent authorities (if necessary).
Refund and fee questions:
* AML refund fee: up to 5% of the amount (maximum $100).
* For bona fide clients (KYC/SoF verified), only network fees are charged.
* Return is not possible if assets are seized at the request of the authorities or are deemed illegal.
* Failure to verify will result in termination of service.
6. Internal control and legal conditions
Compliance organization:
* Responsible person: AML officer.
* Staff training: annual.
* Audit: quarterly (it is possible to involve external experts).
Legal status:
*The policy is part of the Mchanger User Agreement.
* The service reserves the right to change the terms unilaterally by publishing them on the website.
* Using the service means you agree with this document.
Contact information:
Requests to the AML officer and reports of suspicious activity should be sent to: [email protected]
Date of update: January 8, 2026
© Mchanger, 2026
