Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy

Cryptocurrency exchange service Btcrotor.net

Effective date: January 5, 2026

Basis : International FATF standards and national legislation of the countries of presence

Section 1. Objectives and principles of policy

Btcrotor.net (hereinafter referred to as the "Platform") adheres to the highest standards of financial compliance. This Policy is aimed at:

- Preventing the use of the platform for illegal purposes;

- Ensuring compliance of activities with regulatory requirements;

- Protecting business reputation and strengthening user trust;

- Compliance with FATF recommendations and the laws of the jurisdictions where the Service operates.

Section 2. User Identification and Verification (KYC)

2.1. Mandatory nature of the procedure

Access to platform functionality beyond established limits is granted only after verification. Btcrotor uses external KYC providers to validate user data. The identification process is divided into two levels, which determine transaction limits:

• Level 1 — Basic Verification. Includes verification of email address, identity documents, and registered address. Applicable to standard banking transactions not considered high-risk.
• Level 2 — Extended Verification. Initiated when there are signs of increased risk or a corresponding AML status. The list of documents may be supplemented by a requirement to confirm the source of funds.

The right to request documents as part of an extended check remains with the service and is exercised based on the results of an individual risk assessment.

2.2 Verification of the source of funds

When completing extended identification, the User is required to provide documentary proof of the legal origin of assets. The list of accepted documentation is open and may include:

• confirmation of employment income (certificates, contracts, tax returns);
• bank statements recording the receipt of funds;
• evidence of investment income (dividends, etc.);
• property alienation agreements (real estate, transport);
• certificates of inheritance or gift agreements;
• Business activity reports. The Service reserves the right to request additional information or other documents on an individual basis based on the results of the risk assessment.

2.3. Required documents for client verification

To confirm your identity (optional):

- Internal passport of a citizen (ID card) ;

- International passport;

- Driver"s license.

To confirm your address (optional):

- Lease agreement (certified) or bank statement;

- Utility/electricity bills;

- Tax return;

- Other official documents indicating the address of residence for the last 3 months.

Document requirements:

- Data must be duplicated in Latin transliteration;

- Documents must be valid, reliable and independent;

- Mandatory customer selfie with a "Btcrotor.net" sign, current date and personal signature.

2.4. Categorization of clients by risk level

The following are automatically considered high risk:

- PEP (politically exposed persons) and their relatives;

- Residents of countries from the FATF High-Risk Jurisdictions list.

2.5. Additional Provisions

- The platform reserves the right to request re-verification in case of suspicious activity;

- Users from jurisdictions blacklisted by FATF, OFAC, EU, UN ( Appendix No. 1) are not served;

- Verification time: standard - 1–24 hours, extended (EDD) - 24–72 hours.

Section 3. Monitoring of Operations (KYT)

3.1. Analysis tools

Btcrotor.net uses automated and manual methods of transaction verification through specialized providers (including AMLBot and similar ones).

3.2. Risk assessment criteria

The check is carried out according to the following parameters:

1. Connection with sanctions lists: addresses from “black” clusters (darknet, fraud, stolen funds);
2. Using anonymizers: mixers, toggle switches, protocols;
3. Suspicious patterns:

- Fractional transfers (smurfing);

- Operations from high-risk jurisdictions;

4. Risk scoring: assignment of Low/Medium/High level.

3.3. Risk assessment scale (example)

- Low: score ≤ 62% according to the provider model;

- Medium: score 63% - 70%;

- High: score 71% - 75%.

Ratings are subjective and depend on the provider"s methodology.

Marking operations High Risk transactions can be blocked automatically and transferred to an AML officer for manual review.

Preliminary address check: https://www.bestchange.com/report/

Section 4. Service Obligations and Warranties

Btcrotor.net undertakes to:

1. Implement KYC/KYT procedures and risk assessment;
2. Monitor operations and block transactions when AML/CTF threats are identified;
3. Transfer information to authorized bodies in cases established by law;
4. Store customer and transaction data for at least 5 years;
5. Regularly train staff on compliance standards;
6. Ensure the legitimacy of assets sent to clients.

Requirements for outgoing transactions:

- Use of unique (one-time) crypto addresses;

- Sending only to addresses with low risk according to AML analysts;

- Priority to addresses of licensed platforms.

All payments comply with the requirements of FATF, OFAC and other international regulators.

Section 5. Actions upon detection of suspicious activity

If signs of illegal activity are detected, the Platform:

1. Immediately suspends the operation;
2. Blocks the account until the investigation is completed;
3. Generates an internal report (SAR/STR);
4. If necessary, notifies the competent authorities (Rosfinmonitoring, FinCEN, EU FIU, etc.).

Refunds and fees:

- Commission for return of AML cases: up to 5% of the amount, but not more than $100;

- Return is not possible if the assets are found to be related to illegal activities or are subject to seizure at the request of the authorities;

- For bona fide clients who have passed KYC/SoF, the commission is limited to network fees.

Refund time requirements: 7-10 business days.

A client"s refusal to provide information or failure to undergo verification is grounds for termination of service.

Section 6. Working with contractors and partners

Platform:

- Does not cooperate with services from jurisdictions with weak AML regulation;

- Conducts due diligence of all partners (exchanges, payment gateways, API providers);

- Requires contractors to have licenses and comply with international standards.

Section 7. Data protection and storage

All personal and transactional data:

- Encrypted according to industry security standards;

- Stored on secure servers in GDPR and MiCA compliant jurisdictions;

- Available to authorized personnel only;

- Retained for at least 5 years after the termination of the relationship with the client (unless the law requires a different period).

*This privacy policy applies to the Btcrotor.net website and mobile app.

Section 8. Internal Control and Training

1. Responsible for the Policy – AML officer (contact: support@btcrotor.net);
2. All employees undergo annual AML/CTF training;
3. Quarterly internal audits with the involvement of independent experts if necessary.

Section 9. Final Provisions

- This Policy is part of the Btcrotor.net User Agreement;

- The Service reserves the right to make changes unilaterally by notifying users via the website;

- Use of the Platform services constitutes automatic agreement with the terms of this Policy.

Contact information for reporting suspicious activity: support@btcrotor.net

Responsible AML officer: support@btcrotor.net

© Btcrotor.net, 202

*Appendix No. 1

Prohibited Jurisdictions (High AML Risk)

Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma), as well as all territories included in the sanctions lists of FATF, OFAC, EU and UN on the date of the operation.