AML Policy El Sabah For Exchange

Content

• 1. General Provisions
• 2. Transaction Monitoring and Control
• 3. High-Risk Parameters
• 4. Actions Upon Identification of High-Risk Items
• 5. Refunding High-Risk Funds
• 6. Denial of Service
• 7. Denial of Service to Reduce Risks
• 8. Dispute Resolution
• 9. Information Storage

1. General Provisions

The El Sabah For Exchange AML Policy governs the activities of the exchange service with respect to combating money laundering and the use of the service for the purpose of legalizing criminally obtained funds. The policy is based on the FATF (Financial Action Task Force on Money Laundering) Recommendations.

2. Transaction Monitoring and Control

Based on this AML Policy, the exchange office conducts analysis, monitoring and control of transactions (AML verification) carried out using the El Sabah For Exchange service.

3. High-Risk Parameters

When checking transactions for anti-money laundering, the exchange office focuses on high-risk parameters:

• Child Exploitation
• Fraud Shop
• High-Risk Jurisdiction
• Illicit Actor/Organization
• Terrorism
• Dark Service
• Dark Market
• Exchange Fraudulent
• Scam
• Illegal Service
• Stolen Funds
• Mixer
• Ransomware/Malware
• Enforcement Action
• Gambling
• Protocol Privacy
• Bridge
• Decentralized Exchange
• Sanctions
• Prohibited platforms: Capitalist, CommEx, Garantex, Bitpapa.com, NetEx24.net, Rapira.net, Vexel, Fun Pay, Web Money, Freekassa, Yobit, exmo.com, exmo.me, Crypto Cloud, Cripta, BitBits, Nix Money, Bixter, Payeer.com

Also, in the case of frozen transactions for the above reasons and platforms, the review period may be significantly longer than the standard established time limits.

4. Actions Upon Identification of High-Risk Items

If a detailed analysis reveals the presence of high-risk parameters:

1. Stop the application and hold the Client's funds until a full investigation is completed (72 hours).
2. To comply with anti-fraud and financial risk requirements, the service may request the user's personal information.

5. Refunding High-Risk Funds

Refunds for high-risk clients are only issued upon provision of personal information.

• 5.1. Refunds are made only to the details specified in the application.
• 5.2. The return method is determined by the exchange office depending on technical capabilities.

6. Denial of Service

The exchange office reserves the right to refuse further service to the client if high-risk transaction parameters are identified.

7. Denial of Service to Reduce Risks

The Service reserves the right to refuse to provide exchange services at any stage if there is a suspicion that the exchange is related to money laundering, terrorist financing, or other illegal activity in accordance with the laws of the country where the Service is hosted, the User's country of residence, or international law.

8. Dispute Resolution

The parties to the offer undertake to resolve any disputes under these Rules through negotiations. Failure to reach an agreement will result in disputes being resolved in accordance with the laws of the country where the Respondent is located.

9. Information Storage

Information on exchange transactions is stored in the Service's database and is a priority source in case of disputes.