Anti-Money Laundering and Know Your Customer Policy
This Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML / KYC Policy”) has been developed to prevent and mitigate the risks of involving the service https://rateon.io/ (hereinafter referred to as “RateON”, the “Website”, the “Service”) in illegal activities, including money laundering, terrorist financing, and other unlawful actions.
This Policy is developed and applied in accordance with the applicable legislation of the Republic of Cyprus, taking into account international AML/CFT standards, as well as, with respect to the processing of personal data, applicable data protection laws (including, where applicable, GDPR).
User Warning
In the field of digital asset circulation, AML checks and compliance procedures may result in delays in processing requests, requests for additional documents, and/or temporary suspension of transactions. Certain checks may be performed by automated systems and/or third-party providers, and the duration of specific checks may depend on responses from third parties (payment systems, exchanges, AML providers) or requirements of authorized authorities.
Definitions
Website / RateON — an online platform for exchanging digital (electronic) currencies located at https://rateon.io/, including subdomains, APIs, and other access tools related to this Website.
Services — procedures for exchanging digital (electronic) currencies carried out using the functionality of the Website.
User — any visitor of the Website. The User confirms that they are at least 18 years old, that the laws of their country of residence do not prohibit the use of the Website, and that they do not intend to use the Services for illegal purposes.
Administration — authorized persons responsible for managing the RateON Website.
Personal Data — any information relating to an identified or identifiable natural person.
Order — a request submitted by the User for the purchase or sale of digital (electronic) currencies using the Website Services.
The Website may restrict or refuse to provide Services to persons and/or transactions associated with high-risk jurisdictions, sanctioned jurisdictions, or other restrictions established by applicable legislation and/or the Service’s compliance policies.
1. Purpose of Internal Regulation
1.1. The Service https://rateon.io/ applies measures and procedures aimed at preventing money laundering and terrorist financing.
1.2. The purpose of these measures is to prevent the use of the Website for illegal purposes and to comply with applicable legislation and international AML/KYC standards.
2. Warning
2.1. The Service https://rateon.io/ warns against using the Website for money laundering, terrorist financing, fraud, as well as for the acquisition of prohibited goods and services.
2.2. RateON takes reasonable and available measures to prevent illegal activities; however, it cannot guarantee the absence of unlawful actions by third parties.
2.3. The User acknowledges and agrees that in the digital asset sector, decisions to assign an increased risk level to transactions may be made by automated systems and third parties over which the Service has no direct control. RateON acts in good faith and within its capabilities to protect Users’ interests and comply with legal requirements.
3. Requirements
3.1. In order to prevent illegal operations, the Website establishes the following requirements for all Orders:
3.1.1. The sender and the recipient of funds under an Order must be the same person. Transfers to third parties using the Website Services are prohibited.
3.1.2. All contact details and other Personal Data provided by the User must be current, accurate, and truthful.
3.1.3. Users are not recommended to split (fragment) funds sent from a single address or source into multiple Orders. Such actions may be regarded by automated monitoring systems as suspicious activity and may lead to additional verification or suspension of Order processing, even if previous transactions from the same address did not pose increased risk.
4. Verification Procedures
One of the international standards for preventing illegal activities is customer due diligence (hereinafter referred to as “Verification”). The Website applies customer verification procedures within the AML/KYC policy.
4.1. In the event of triggering automated monitoring systems, identification of increased risk, transaction suspension, and/or conducting additional verification within the AML/KYC policy, the Service https://rateon.io/ has the right to request documents and information from the User to confirm identity and sources of funds, including but not limited to:
- a high-quality photograph of the User’s identity document;
- a photograph of the User holding the specified document;
- confirmation of employment status;
- confirmation of sources of funds;
- video identification of the User;
- video materials/information confirming the transaction, including hash, sender and recipient addresses, amount, and transaction date.
4.2. The Service https://rateon.io/ applies automated and/or manual AML transaction analysis using a risk-based approach. For internal control purposes, threshold values (including indicative risk score thresholds) determined by internal procedures and/or AML providers may be applied. Transactions classified as high-risk may be suspended for verification and/or investigation.
4.2.1. High-risk categories may inсlude, among others, transactions associated with the following categories:
illegal service, mixing service, fraudulent activity, darknet marketplace, darknet service, ransom, scam, stolen coins, terrorism financing, sanctions, illicit actor or organization, high-risk jurisdiction, gambling, fraud shop, enforcement action, child exploitation.
4.3. The Service https://rateon.io/ recommends that Users contact customer support in advance for AML address checks before creating an Order.
4.4. In the event of transaction suspension due to increased risk, suspicious activity, or an official investigation, funds may be held until verification or investigation is completed, to the extent and for the period permitted by applicable law.
4.5. The Website has the right to collect and process User identification information for the purposes of complying with the AML/KYC Policy.
4.6. The Service takes measures to verify the authenticity of the provided documents and has the right to conduct additional checks if suspicious activity is detected.
4.7. The Website has the right to conduct repeated or periodic User identity verification, including requesting updated documents, if required by internal procedures and/or applicable legislation.
4.8. User identification information is processed and stored in accordance with the Privacy Policy of RateON and applicable legislation. Data retention periods are determined by legal requirements and/or internal record-keeping procedures, as well as the terms of interaction with payment partners and AML providers.
4.8.1. With respect to personal data, where data protection legislation applies, the User may have rights of access, rectification, updating, and other rights provided by law; the procedure for exercising such rights is described in the Privacy Policy.
4.9. Upon completion of verification, the Website has the right to refuse to provide Services in the event of выявление illegal use of the service or other grounds provided by applicable legislation and/or this Policy. In such cases, the User may receive a refund subject to applicable fees and legal requirements, provided there is no prohibition by authorized authorities.
4.10. The Service https://rateon.io/ has the right to verify the sources of origin of financial funds and digital assets.
4.11. The Service may not have complete information about the reasons for assigning a transaction a higher risk level, as the assessment may be carried out by automated systems and/or third-party providers. In certain cases, disclosure of such details may be restricted by the terms of use of relevant systems and/or legal requirements.
5. Responsible Officer
5.1. Compliance with AML/KYC requirements is overseen by an authorized officer of RateON.
5.2. The responsibilities of such officer inсlude monitoring compliance with the AML/KYC policy, transaction monitoring, interaction with law enforcement authorities, and updating risk assessment procedures.
6. systеm Functions
6.1. The Service https://rateon.io/ uses monitoring and analysis systems, including:
- screening against sanctions and watchlists;
- transaction activity monitoring;
- record-keeping and investigations;
- report generation where required.
7. Behavioral Analysis
7.1. The Service analyzes User behavior in transactions to detect suspicious activity and assess risks.
8. Risk Assessment
8.1. The Website applies a risk-based approach in accordance with international AML/CFT standards and the applicable legislation of the Republic of Cyprus.
9. Execution of User Checks
9.1. If there are reasonable suspicions, the Administration has the right to:
- analyze transaction chains;
- suspend operations for the duration of the investigation, which may exceed specified timeframes if objectively justified;
- request additional documents and information;
- transfer information to authorized authorities in accordance with the law.
9.2. Based on the results of the investigation, the Administration makes a decision to continue the operation or refund funds in cases permitted by applicable legislation.
9.3. In the event of a positive decision, the exchange rate may be recalculated at the time of completion of verification.
9.4. The User is obliged to confirm the details required for refund or exchange of funds.
9.5. The standard internal verification period is up to 7 (seven) business days. In cases where verification involves requests to authorized authorities, third-party payment systems, exchanges, or AML providers, the review period may be extended for the time necessary to receive relevant responses. Such timeframes may not depend on the Service and are determined by third parties and/or legal requirements.
9.6. During the verification process, the Service, where possible, informs the User about the status of the Order review and requests additional information if permitted by applicable law.
10. Confidentiality
10.1. The Service https://rateon.io/ processes information in accordance with the Privacy Policy.
10.2. Confidentiality of information regarding suspicious transactions is maintained to the extent permitted by applicable legislation.
10.3. Confidentiality obligations remain in force after termination of relationships with employees or counterparties.
10.4. Disclosure of information is permitted in cases provided by law or within the framework of cooperation with authorized authorities and partners.
11. Conclusion
RateON takes reasonable measures to prevent the use of the Service for illegal purposes and to comply with AML/KYC requirements. By using the Website Services, the User confirms acceptance of this Policy and undertakes to comply with it.