1.1. This AML / KYC / SoF Policy defines the procedure for reviewing transactions, digital currency addresses, payment details, the User identity, the source of funds, and other circumstances relevant to the security of orders on coindrop.trade.

1.2. "COINDROP", "Service", or "We" means the online service coindrop.trade and the person administering the operation of the Service. "User", "Customer", or "You" means the person using the website, creating an Order, or participating in its execution.

1.3. This Policy is part of the COINDROP user documents and applies together with the Rules and Terms of Exchange Operations, the Privacy Policy, and the terms of a specific Order. Creating an Order, ticking the checkbox confirming acceptance of the documents, or otherwise actually using the Service means acceptance of this Policy.

1.4. The Service applies risk-based control as an internal security measure, for good-faith transaction review, protection of Users, and interaction with partners, monitoring platforms, banks, payment systems, and competent authorities. This does not mean that the Service has any special regulated status unless such status is expressly stated on the website.

1.5. The Service is not a bank, credit institution, payment system operator, money transfer operator, broker, dealer, mining operator, mining pool organizer, or digital financial asset exchange operator unless such status is expressly stated on the website. Digital currency within the Service is considered only as the subject of exchange under an Order.

1.6. The Service may refuse to create or execute an Order, suspend processing, request additional materials, offer replacement payment details, or arrange a refund if this is necessary for security, AML / KYC / SoF, legal compliance, partner rules, sanctions restrictions, or fraud prevention.

1.7. This Policy is not a public offer to accept any assets, addresses, transactions, or payment details and does not guarantee the creation, execution, or restoration of an Order where AML / KYC / SoF risks are present.

1.8. The availability of an exchange direction on the website, a preliminary calculation, a preliminary AML check, the issuance of payment details, or a Support message does not cancel the right of the Service to conduct a review and make a decision based on the actual circumstances of the transaction.

2.1. AML check - analysis of an address, TxID, transaction, transaction chain, payment details, exchange direction, and other indicators to assess the risk of money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful activity.

2.2. KYC - verification of the User identity, data, ownership of payment details, connection with the Order, and the right to dispose of assets or funds.

2.3. SoF - confirmation of the source of funds, the economic purpose of the transaction, the history of acquiring the assets, income, ownership of a wallet, account, card, bank account, or other payment details.

2.4. AML analyzer - a software product, blockchain analytics service, monitoring report, internal Service system, or other tool used to assess the risk of transactions, addresses, sources, and links.

2.5. Risk-Score - a risk assessment of a transaction, address, TxID, User, or payment details expressed as a percentage, score, category, Low / Medium / High label, or another scale used by an AML analyzer or the internal procedures of the Service.

2.6. AML-Hold - temporary suspension of execution of an Order or specific actions related to it until the review is completed, documents are received, a third-party response is obtained, or the Service makes a decision.

2.7. Critical AML labels - indicators of links to sanctions, terrorism, darknet, mixers, ransomware, scams, stolen funds, fraud, illegal gambling, illegal brokers, hacks, theft, extortion, deception, or other high-risk sources.

3.1. The Service assesses risk not by a single indicator, but by the totality of circumstances: Risk-Score, AML analyzer labels, amount, exchange direction, network, source of funds, country, User behavior, payment details, request history, documents, and data from banks, payment systems, monitoring platforms, and partners.

3.2. Risk thresholds, the list of labels, factor weights, internal routing rules, the list of AML analyzers used, and technical review parameters may differ depending on exchange directions, amounts, networks, partners, and the current risk model. The Service is not required to disclose internal algorithms if such disclosure may reduce the effectiveness of control or create a risk of bypassing checks.

3.3. The Service may use BitOK, BestChange AML Report, other external AML tools, internal lists, data from partners, monitoring platforms, banks, payment systems, open sources, and its own operational observations.

3.4. A preliminary AML check of an address, TxID, or wallet on the website is informational and is not a final decision of the Service. Risk may be identified later based on the actual TxID, sending source, route of funds, payment details, bank, User behavior, a request from a monitoring platform, or third-party data.

3.5. A review may be carried out before payment details are issued, after an Order is created, after funds are received, before payout, after a disputed payment is identified, or upon a request from the User, a monitoring platform, bank, payment system, partner, or competent authority.

4.1. The Service may apply AML-Hold in case of a high Risk-Score, critical labels, a combination of medium risks, mismatched User data, use of third-party or non-standard payment details, suspicious splitting of transactions, repeated cancellations, disputed payments, or atypical behavior.

4.2. Grounds for AML-Hold also include links to sanctions, darknet, mixers, ransomware, scams, stolen funds, terrorism financing, fraud, illegal gambling, unlicensed platforms, suspicious P2P sources, hacked wallets, fake tokens, fake balances, or unreliable TxIDs.

4.3. AML-Hold may be applied upon a request from a bank, payment system, monitoring platform, partner, right holder, affected person, or competent authority, as well as in the event of a complaint, payment reversal, chargeback, fraud report, or signs of an attempt to receive funds twice.

4.4. If digital currency is sent from an exchange, custodial wallet, hot wallet, payment service, wallet with dynamic addresses, or other infrastructure, the actual sending address may differ from the address specified by the User. Such a mismatch is not always a violation in itself, but the User must explain it and provide confirmation upon request.

4.5. The Service may refrain from executing an Order until the review is completed if there are signs that the transaction may be linked to unlawful activity, disputed funds, an erroneous payment, third-party payment details, social engineering, or pressure from third parties on the User.

5.1. Depending on the risk, the Service may request one or more materials: an identity document, a selfie or video with the document, confirmation of ownership of a card, bank account, SBP, e-wallet, crypto wallet, address, exchange account, or other payment details.

5.2. To confirm a transaction, the Service may request a receipt, PDF payment receipt, bank statement, transaction certificate, TxID, transaction history, app screenshots, video recording of transaction history, or confirmation that funds were actually received or not received.

5.3. For SoF, the Service may request information about the origin of funds, the economic purpose of the transaction, source of income, history of asset ownership, exchange, wallet, platform, counterparty, route of funds, and other explanations sufficient to assess the risk.

5.4. Materials must be readable, complete with respect to the transaction under review, and must not be edited in a way that hides material data. The Service may refuse service if materials are forged, altered, contradictory, incomplete, or unreliable.

5.5. The Service does not request, and the User must not provide, passwords, one-time codes, CVV, the full bank card number, seed phrases, private keys, recovery codes, device access, or data that allows disposal of the User funds. If such data is requested by a third party, the User must stop communication and contact Support through the official channel.

5.6. During video confirmation or app demonstration, the User must hide unnecessary data and show only information related to the transaction under review. The Service may request the material again if the quality, scope of data, or recording method does not allow the review to be completed.

5.7. Refusal to provide materials, ignoring requests, or providing incomplete documents does not create an obligation for the Service to automatically execute the Order, remove AML-Hold, replace payment details, or return funds without review. A refund and other resolution may also require confirmation of ownership of the address or payment details and admissibility of the transaction.

6.1. It is prohibited to use the Service for money laundering, terrorist financing, sanctions evasion, fraud, carding, scams, extortion, ransomware, trading stolen data, darknet, mixers, illegal gambling, unlicensed brokers, pyramid schemes, fake investment platforms, or any other unlawful activity.

6.2. It is prohibited to create an Order at the request of unknown persons, fake brokers, representatives of pseudo-exchanges, dubious investment projects, bank security departments, persons promising income for transferring funds, or other third parties who may use the User to withdraw funds, deceive others, or bypass restrictions.

6.3. It is prohibited to use third-party, corporate, nominee, rented, stolen, front-person, or otherwise unavailable payment details unless otherwise agreed in advance with the Service and allowed by the selected exchange direction.

6.4. It is prohibited to provide forged receipts, altered payment receipts, fake TxIDs, screenshots of fictitious balances, interfaces of fake wallets or exchanges, or to conceal the fact of a payment reversal, bank block, third-party complaint, or disputed origin of funds.

6.5. Violation of this section is grounds for AML-Hold, refusal of service, cancellation of the Order, refund to verified payment details, transfer of information to monitoring platforms, partners, or competent authorities within the law, and recovery of direct losses where such losses exist.

7.1. If risk indicators are identified, the Service notifies the User through an available communication channel, unless such notice is prohibited by law, third-party requirements, or the circumstances of the review. The notice may specify the list of materials required to continue processing.

7.2. The estimated timeframe for the initial review is up to 24 hours after receipt of all requested materials. In complex cases, the timeframe may be extended to 7 calendar days.

7.3. The review timeframe may be extended for the period of waiting for a response from a bank, payment system, exchange, wallet, partner, monitoring platform, AML analyzer, competent authority, or other third party, if without such response it is not possible to safely complete the Order, refund, or refusal.

7.4. If the User does not provide the requested materials, provides them partially, does not respond to requests, changes explanations, or sends contradictory data, the review timeframe is not considered to be violated by the Service.

7.5. Until the review is completed, the Service may suspend payout, refund, replacement of payment details, recalculation, restoration of the Order, or any actions that may increase risk for the Service, the User, partners, or third parties.

8.1. Based on the results of AML / KYC / SoF, the Service may execute the Order, continue processing, request additional materials, offer replacement of an address or payment details, perform recalculation, arrange a refund, refuse service, or keep AML-Hold in place until lawful resolution of the situation.

8.2. If the risk is related to a specific address, wallet, payment method, bank, or payment details, the Service may offer the User to replace it with another verified address or payment details. Such replacement is allowed only after ownership is confirmed and the new address or payment details are checked.

8.3. If the User refuses the review, provides unreliable materials, fails to confirm ownership of funds or payment details, or the risk is deemed unacceptable, the Service may refuse to execute the Order and provide further service.

8.4. The Service is not required to disclose detailed results of AML analyzers, internal triggers, exact thresholds, review logs, third-party data, address infrastructure, or information whose disclosure may violate the law, rights of other persons, partner rules, or the security of the Service.

8.5. The decision of the Service may be reviewed upon receipt of new documents, an official response from a bank, payment system, monitoring platform, partner, competent authority, or other materials that materially change the risk assessment.

9.1. A refund is possible if it is technically available, does not conflict with AML / KYC / SoF, legal requirements, rules of a bank, payment system, blockchain network, partner, monitoring platform, or competent authority, and if ownership of the refund payment details or address is confirmed by the User.

9.2. As a general rule, a refund is made to the original payment details of the sender or the original address, if this is possible and safe. A refund to alternative payment details or address is allowed only after additional verification of ownership and admissibility of such refund.

9.3. In case of a refund, actual costs related to the refund are withheld, including network, bank, payment system, partner fees, or other documented costs if they arise. For a good-faith User whose funds are not confirmed by the review to be linked to unlawful sources, deductions are limited to the actual refund costs.

9.4. The estimated refund timeframe after a decision is made and correct payment details are received is up to 3 business days, unless a longer period is caused by AML-Hold, verification of payment details, operation of a bank, payment system, blockchain network, partner, monitoring platform, competent authority, or the need for additional verification.

9.5. If a refund is related to critical risks, sanctions match, third-party complaint, request from a bank, payment system, monitoring platform, partner, or competent authority, the Service may postpone the refund until lawful resolution of the situation or perform the refund only in the manner agreed as part of the review.

9.6. Failure to provide documents, refusal of KYC / SoF, or a request to return funds to unverified payment details does not create an obligation for the Service to perform a refund bypassing the review. Until ownership of the payment details, admissibility of the refund, and absence of a prohibition from third parties are confirmed, the refund may be suspended.

10.1. The Service takes reasonable measures to check outgoing digital assets and does not use for payouts sources that, according to the data available to the Service, are directly or indirectly linked to critical AML risks or unlawful activity.

10.2. To execute Orders, the Service may use its own operational infrastructure, verified partners, verified platforms, operating addresses, consolidation addresses, dynamic or unique addresses, and other technical solutions necessary for security, liquidity, execution of Orders, and AML control.

10.3. The Service may change the source, route, address, or payout method if this reduces risk, increases execution reliability, or is necessary due to requirements of a partner, bank, payment system, blockchain network, monitoring platform, or competent authority.

10.4. The full structure of operating addresses, routes, partners, liquidity sources, and internal procedures is not published publicly if disclosure may create a risk of infrastructure blocking, attacks, bypassing checks, pressure on partners, or violation of third-party rights.

10.5. Upon request of a monitoring platform, partner, bank, payment system, or competent authority, the Service may provide supporting materials in a reasonable scope: TxID, AML report results, description of the address model, information about the execution source, or other data necessary to review the situation. The Service is not required to disclose information beyond the necessary scope if this violates the rights of other Users, confidentiality, infrastructure security, or partner rules.

11.1. AML / KYC / SoF materials are used to execute the Order, conduct security checks, prevent fraud, review requests, interact with partners, monitoring platforms, banks, payment systems, and competent authorities, and protect the rights of the Service and Users.

11.2. Personal data is processed in accordance with the Privacy Policy published on the website. Access to materials is limited to employees, representatives, or partners who need such data for review, execution of the Order, security, legal recordkeeping, or compliance with applicable requirements.

11.3. The Service may store documents, logs, receipts, correspondence, AML analyzer results, review decisions, and materials related to disputed transactions for the period necessary to execute the Order, protect rights, respond to requests, interact with third parties, and comply with applicable requirements.

11.4. The Service takes reasonable organizational and technical measures to protect review materials. At the same time, the User must independently protect their devices, email, messengers, wallets, exchange accounts, banking apps, and communication channels.

12.1. The Service may change this Policy, review rules, AML tools used, risk model, list of documents, timeframes, and interaction procedure. Changes take effect from the moment of publication on the website unless another effective date is specified in the new version.

12.2. The new version of the Policy applies to Orders created after its publication. Orders already created are governed by the version in effect at the moment the Order was created, unless the change is related to mandatory legal requirements, AML / KYC / SoF, sanctions, security, force majeure, orders of competent authorities, or prevention of an unlawful transaction.

12.3. The fact of acceptance of the Policy, document version, date and time of acceptance, IP address, email, Order number, Order parameters, checkbox mark, and technical actions of the User may be recorded in the Service logs and used to confirm the terms in effect at the moment of creation or processing of the Order.

12.4. If any provision of the Policy is found invalid or unenforceable, this does not affect the validity of the remaining provisions.

12.5. Current legal information is available on the page https://coindrop.trade/legal-information. The Rules and Terms of Exchange Operations are available on the page https://coindrop.trade/siterules. The Privacy Policy is available on the page https://coindrop.trade/privacy-policy.

12.6. For questions related to review, AML-Hold, documents, and disputed transactions, the User may contact Support at support@coindrop.trade or through the online chat on the website.