AML / CTF & KYC

AML and KYC Policy of the Groza Exchange Service

1. General Provisions

1.1. The Groza Exchange Service operates in accordance with international AML/CFT standards and applies a risk-based approach.

1.2. AML control functions are implemented by automated systems and designated service employees.

1.3. The Service reserves the right to suspend transactions for checks as part of AML/KYC/SoF procedures.

2. Risk Assessment Model (Risk-Score)

2.1. All incoming transactions undergo a risk assessment (Risk-Score), generated based on data from AML analyzers.

2.2. The Risk-Score takes into account:

- the origin of funds;

- connections to high-risk sources (including, but not limited to: scams, dark markets, enforcement actions, and similar categories);

- transaction history;

- behavioral factors.

2.3. Risk-Score Thresholds:

- up to 50% — the transaction is processed as standard;

- 50–60% — the transaction may be suspended for additional verification;

- over 60% — the transaction is blocked until mandatory verification is completed.

2.4. If the threshold is exceeded:

- the transaction is temporarily blocked;

- KYC and SoF procedures are initiated.

3. AML/KYC Systems Used

3.1. The Sumsub service is used for user identification.

3.2. The GetBlock AML analyzer (including, but not limited to, Chainalysis/Crystal/similar solutions) is used for transaction analysis.

3.3. The results of these systems are used for:

- calculating the Risk-Score;

- making decisions on transactions;

- identifying suspicious transactions.

4. Verification Procedure (KYC/SoF)

4.1. If necessary, the user is required to undergo verification via SumSub.

4.2. The following may be requested:

- ID;

- selfie/video verification;

- proof of address;

- documents on the origin of funds (SoF);

- transaction history;

- other materials upon request.

4.3. Refusal to verify will result in the inability to complete the transaction.

5. Verification Stages and Timeframes

5.1. Verification includes:

- automatic AML analysis;

- transaction suspension (if necessary);

- data request;

- verification via SumSub;

- decision making.

5.2. Timeframes:

- initial analysis - up to 2 hours;

- KYC — up to 48 hours;

- additional verification — up to 72 hours;

- in exceptional cases — up to 5 business days.

6. Refunds and Fees

6.1. If a transaction is declined, funds may be returned to the sender.

6.2. Refund Conditions:

- KYC/SoF verification;

- no legal restrictions.

6.3. AML Fee:

- up to 5% of the amount, but no more than the equivalent of 100 USD.

- In some cases, only the network fee is withheld.

6.5. Refund Period:

- from 1 to 10 business days after the decision is made.

7. Preliminary AML Check

7.1. The website offers the option of preliminary AML check of transactions.

7.2. The user can:

- undergo a paid verification through the integrated service or the BestChange verification page https://www.bestchange.ru/report/;

- transfer the results to the operator;

- refuse verification by confirming acceptance of the risks (using the checkbox).

7.3. If the user refuses the preliminary verification, they assume the risk of being blocked.

8. Personal Data Processing Policy

8.1. The Service collects and processes personal data in accordance with a separate Privacy Policy.

8.2. User data:

- is transmitted through secure channels;

- is stored in encrypted form;

- is processed using technical and organizational security measures.

8.3. Data received through SumSub is processed in accordance with its security standards.

9. Final Provisions

9.1. Using the Service constitutes the user's consent to this policy.

9.2. The Service reserves the right to make changes.

9.3. The current version is published on the website.