AML Policy
AML/KYC Policy
This regulatory document implements a comprehensive set of rules and procedures aimed at preventing the legalization (laundering) of proceeds from crime and the financing of terrorism. Furthermore, it defines the regulations for customer identification and transaction monitoring. The primary purpose of applying this policy is to protect the 2rbina.net platform and its Users from any involvement in unlawful or illegal activities. Every Order, without exception, is subject to a mandatory AML check. The User has the right, on their own initiative and prior to the actual dispatch of funds, to independently verify their crypto wallet's compliance with AML standards using a specialized AML checker. If the User does not possess information regarding the wallet address and/or lacks the ability or desire to initiate a preliminary AML check, then in the event that the aggregate AML risk level exceeds 55%, the exchange operation shall be immediately suspended. In such a situation, the funds are subject to a refund (minus the network fee) in accordance with the procedure stipulated by the User Agreement.
Terms and Definitions 2rbina.net is classified as an online platform providing services for the exchange, purchase, and sale of cryptocurrencies, as well as other digital assets. User — a natural or legal person actually utilizing the functional capabilities and services of the 2rbina.net platform. Cryptocurrency — a specific type of digital currency, the functioning of which is based on distributed ledger technology (blockchain). Electronic currency — funds circulated within electronic payment systems. Money laundering — the process of legalizing financial assets obtained through illegal or criminal means. Terrorism financing — the process of providing resources (financial or material) intended for the preparation and execution of terrorist acts.
Procedure for Preliminary AML Check of a Crypto Wallet Prior to forming an exchange order, the User has the right to independently analyze their crypto wallet using the AML checker. To perform such a check, registration on the website and the purchase of the corresponding verification package in the Personal Account are required. 2.1. Website Registration Regulations To gain access to the AML checker functionality, the User must first create an account:
Open the registration page.
Enter the following credentials: a valid email address; and a secure password;
Complete the registration procedure by navigating to the unique link sent to the specified email address. Upon successful confirmation, the User is granted full access to the Personal Account. 2.2. Regulations for Purchasing an AML Check Package The AML check service is provided exclusively on a paid basis using a package model. To purchase a check package, the User must follow this algorithm: Step 1. Authorize in the Personal Account. Step 2. Click the button labeled "Buy Checks". Step 3. Select the check package that most accurately meets current needs. Step 4. Click the "Proceed to Payment" button. Step 5. The system will automatically generate an address for depositing funds. The User must send the payment to this address. Once the deposit is successfully credited, the balance of available checks will be displayed in the Personal Account, which can be immediately used for AML wallet analysis. 2.3. Regulations for Performing an AML Check Step 1. Navigate to the "AML Checks" section within the Personal Account and click the "New Check" button. Step 2. Specify the exact address of the crypto wallet from which the transfer is planned. Step 3. Select the appropriate network (e.g., BTC, ETH, TRC-20, etc.). Step 4. Click the "Check" button. Thereafter, the system will automatically deduct one check from the purchased package and display the results of the analysis on the screen. 2.4. Regulations for Transmitting the Check Result to the Operator Upon completion of the AML check procedure, its results are automatically sent to the User's registered email. The subsequent algorithm of actions depends directly on the recorded risk level: If the identified risk level does not exceed 55%, the User is granted the right to use this wallet for executing exchange operations without the need to perform any additional procedures. If the risk level exceeds the 55% threshold, the User bears the obligation to transmit the check results to the operator via the online chat located on the website. The message to the operator must obligatorily state: the address of the checked wallet; the exact date of the check; and a brief description of the obtained results. The operator takes the provided information under consideration and subsequently informs the User whether the dispatch of funds from the specified wallet is possible. Important: ignoring system notifications regarding the detection of a high risk level is strictly prohibited, as compliance with them is a mandatory requirement of the service's AML policy.
3. Objectives of This Policy Prevention and preclusion of the platform's exploitation for unlawful or criminal purposes. Guaranteeing full compliance with the requirements of both national legislation and international regulatory standards. Enhancing the security level of Users and ensuring the company's reputational stability.
Structural Components of the Policy 4.1. AML/CTF Conducting customer identification and verifying the origin sources of their financial assets. Implementing continuous transaction monitoring for the prompt detection of any suspicious activity. 4.2. KYC The process of collecting and subsequently verifying personal and financial information about the client. All contact and personal data specified by the User when forming an Order must be comprehensive, reliable, and up-to-date at the time of submission. 2rbina.net assumes obligations for the protection, secure storage, and lawful processing of such data in strict accordance with the terms of the User Agreement and the mandatory norms of applicable legislation. Users' personal data is not subject to transfer to third-party AML providers. For the purpose of conducting transaction analysis, the service is authorized to use automated blockchain analytics software tools. Within the framework of such checks, exclusively technical information about transactions is processed (in particular, crypto wallet addresses and operation hashes), without disclosing any personal identifiers of the User. 4.3. KYT Conducting analysis of transactional activity to promptly detect signs of fraudulent or other illegal operations. The possibility of temporarily suspending suspicious transactions until proper supporting data is received. Verification of the origin sources of financial funds involved in the transaction. 4.4. Regulations for Processing High-Risk Operations To conduct a comprehensive transaction analysis, the service implements automated blockchain analytics systems, the functionality of which allows for the identification of suspicious activity and specific operational risk markers. During the verification process, various transaction risk indicators are analyzed, including probable connections with high-risk sources, fraudulent networks, sanctioned services, and other categories of activity that arouse suspicion. In the event that, based on the results of an automated check, it is established that the aggregate risk level exceeds the 55% threshold, and a connection with high-risk sources (the list of which is provided in clause 4.5 of this policy) is recorded, the transaction may be temporarily suspended. This is done to conduct an in-depth review and make a final decision on returning the funds to the User (deducting the network commission). If a decision is made to return the assets, the execution timeframe for such an operation may reach up to 7 (seven) business days. The final decision regarding the transaction status is based on the results of a comprehensive automated analysis of transactional data and AML/KYT verification data. 4.5. Categories of High-Risk Sources The service is authorized to apply blocking to funds that have been transferred from exchanges on sanctions lists or classified as "high-risk". Currently, this category of platforms includes: MEXC, Black Sprut, BTC-e, Chiper Mixer, DuelBits, FreeBitcoin, Gandhiji.io, Hydra, NVSPC, Roobet, Tornado, WEX Exchange, Yolo Group, OMG!OMG! Garantex, Commex, Tornado Cash, 1xBit, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, MEGA DARKNET MARKET, Primedice, Darknetone, Wasabi Wallet, DuckDice, Doubleway, Stake, Stolen Coins, Fraudulent Exchanges, Terrorism Financing, Bitzlato, Bitpapa.com, NetEx24.net, Trocador.app, Anonexch.io, Cryptomus, nobitex.ir, meer.kg, 1xbet, Aifory.pro, terminal.cash, SkyCrypto.net, FlashObmen.com, 60cek.net, hd-change.com, CoinBlinker.com, Metka.cc, AlfaBit.org, Heleket, payeer.com, Vexel, Fun Pay, Web Money, Freekassa, Yobit, exmo.com, exmo.me, Crypto Cloud, Cripta, BitBits, Nix Money, Bixter, freekassa.ru, kassa.cc, CoinStart, Cripta, Prostocash, arvix.pro (abcex.io), heleket.com, xRocket.tg, CryptoCloud, weiss.bet, BTC-e / FinCEN, Sinbad, OFSI Huobi Global S.A. (HTX.com), as well as resources of other sanctioned jurisdictions and platforms whose activities are focused on ensuring complete anonymity and privacy. This list is not exhaustive and may be expanded. High-risk categories include the following areas: Sanctions, Terrorism, Darknet, Ransomware/Malware, Mixing, Child Abuse, Stolen Funds, Scam/Fraud, Protocol Privacy, Bridge, Decentralized Exchange, Gambling. 2rbina.net is released from any liability for funds received from the aforementioned sources and has the full right to transmit all relevant information to competent government authorities. 4.6. Regulations for Refunding Funds in Case of a Negative AML Check Result If the results of an automated check indicate that the aggregate risk level exceeds 55% and the transaction has a connection with high-risk sources defined in clause 4.5 of this policy, such an operation is subject to temporary suspension. This measure is applied to conduct an in-depth review and make a decision on the procedure for returning funds to the User (deducting the network commission). In the event of applying the AML blocking mechanism, the process of obtaining the final verification status may take up to 24 hours. The direct refund of funds is carried out within up to 7 (seven) business days, starting from the moment the User provides up-to-date wallet data. If the funds have a connection to terrorism, drug trafficking, and so forth, they may be withheld for up to 90 days.
Rights and Obligations of the Service The 2rbina.net platform is authorized to:
suspend and fully block any transactions;
demand that the client provide additional documentation to confirm their identity;
initiate a video verification procedure for the User as an additional identification measure;
transmit the collected data to regulatory or law enforcement structures;
process refunds exclusively to the account from which the initial deposit was made, while simultaneously terminating further cooperation with the client;
An additional fee of up to 5% of the blocked amount, but not exceeding the equivalent of 100 USD, may be charged for the refund procedure.
in a situation where the User does not contact the Service for more than 6 (six) months with a request to return funds that were blocked as a result of AML checks conducted by third parties (in particular, centralized exchanges whose infrastructure is used to execute the Order), make a discretionary decision regarding the form of refund for such assets (this may be a refund in USDT currency or another token, and the exchange rate may be fixed either on the date of Order creation or on the day of the actual refund)