Anti-Money Laundering Policy  

Both international and local regulations and legislation require the PayPerra exchange service to implement effective internal procedures to prevent any illegal activity and to take all necessary measures for this purpose.
 

The PayPerra service adheres to practices in the field of combating money laundering (AML - Anti Money Laundering) and the financing of terrorism, as well as the "Know Your Customer" (KYC) policy.

The AML / KYC policy covers the following issues:

— Verification procedures;

— Transaction monitoring;

— Risk assessment.

1. Verification Procedures

1.1. Identity Verification
 

The verification procedure at PayPerra requires the User to provide the service administration with genuine documents (e.g., international passport, bank statement, utility bill, etc.). For such purposes, PayPerra reserves the right to collect user identification information as part of its anti-money laundering and "Know Your Customer" policies.

Also, PayPerra reserves the right to additionally verify certain Users who have raised suspicion. The verification process includes providing documents that confirm the User's identity.

For individuals:
 

1. To confirm identity, the User must provide one of the following documents:

        — national passport;

        — international passport;

        — ID card.
 

2. To confirm the address, the User must provide one of the following documents:

        — bank statement clearly showing the address of your actual residence;

        — utility bill clearly showing the address of your actual residence;

        — tax documents clearly showing the address of your actual residence;

        — a document confirming the address of your actual residence issued by local authorities, clearly showing the address of your actual residence.

For corporate clients:

1) To confirm identity, the User must provide one of the following documents:

— national passport of the director;

— international passport of the director;

— ID of the director.

2) To confirm the address, the User must provide one of the following documents:

— bank statement clearly showing the address of your actual residence;

— utility bill clearly showing the address of your actual residence;

— tax documents clearly showing the address of your actual residence;

— a document confirming the address of your actual residence issued by local authorities, clearly showing the address of your actual residence.

3) To confirm that the User is an authorized representative of the organization, they must provide all of the following documents:
— a document confirming the legal address of the company;

— document of legal entity registration;

— order of appointment of the director;

— scanned copy or photo of the letter of decision to work with PayPerra.

4) Information about the ultimate beneficiary:

— national passport of the ultimate beneficiary;

— international passport of the ultimate beneficiary;

— ID of the ultimate beneficiary;

— document confirming the address of the ultimate beneficiary. According to Cypriot legislation, the ultimate beneficiary means an individual who owns or controls the user's account and/or an individual on whose behalf transactions are conducted.

1.2. Bank Card Verification

Users who wish to exchange involving a bank card must verify it in advance. Detailed instructions for passing verification can be found here.

2. Transaction Monitoring
 

Users are verified not only by verifying their identity but also by analyzing their transactions. Therefore, PayPerra relies on data analysis as a tool for risk assessment and detecting suspicious user activity.

PayPerra collects data, filters, records, manages investigations, and reports. Regarding AML / KYC policy, PayPerra may monitor all transactions and reserves the right to:
 

— request any additional information and documents from the User in case of suspicious transactions;

— suspend or block the User's account if PayPerra has reasonable suspicions that this User is engaged in illegal activities.

The above list is not exhaustive, and operations will be monitored daily to determine whether transactions should be considered suspicious.

3. Risk Assessment

In accordance with international requirements, PayPerra checks transactions for risk using AML services.
 

In this regard, a transaction may be declined if the overall risk exceeds 50%. Also, the Service may refuse to provide services to the User if the risk exceeds 1.5% in the following categories:
 

— Dark Service — coins related to child abuse, terrorism financing, or drug trafficking;

— Dark Market — coins used for purchases on the dark web;

— Scam — coins obtained by defrauding customers;

— Mixer — coins passed through a mixer to make tracking difficult or impossible, often used for money laundering;

— Illegal Service — coins related to illegal activities;

— Ransom — coins obtained through extortion or blackmail;

— Exchange Fraudulent — coins from exchanges associated with fraud, illegal activities, or assets seized by the government;

— Stolen — stolen coins;

— Gambling — coins associated with unlicensed online gambling.

If a transaction is deemed high-risk, the User must undergo KYC verification to confirm their identity.

4. Conducting Exchanges

PayPerra warns users against attempting to use PayPerra for money laundering, terrorism financing, fraud of any kind, or for purchasing prohibited goods and services.
 

To prevent illegal operations, the Service sets certain requirements for all Applications created by the User:
 

4.1. The sender and recipient of the Payment in the Application must be the same person. Transfers to third parties are strictly prohibited using the Service.
 

4.2. The contact details entered by the User in the Application, as well as other personal data provided by the User to the Service, must be accurate and up-to-date. Upon the User's request, personal data may be deleted from the Service's database within 3 years from the date of the User's last completed Application.
 

4.3. If the Service administration has reasonable suspicions that the user is attempting to use the Service for money laundering or any other illegal operations, the administration has the right to:

— suspend the user's exchange operation;

— request identity documents from the user;

— request other information regarding the payments;

4.4. All information provided by the client may be transferred to regulatory authorities in the following cases:

— upon request from law enforcement agencies;

— by court orders of various instances;

— upon request from Payment System administrations.

Personal data includes:

— surname, first name;

— email address;

— country of residence/citizenship;

— details of the wallets used;

— mobile phone number;

— identity document details;

— address of residence.

4.5. Processing of personal data means recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), including cross-border, anonymization, blocking, deletion, destruction of personal data not falling under special categories, for the processing of which the User's written consent is required.
 

4.6. The processing of personal data is carried out for the purpose of fulfilling obligations under the agreement, registering the User on the website, providing technical support, processing applications, providing service services, considering requests and claims, sending informational and other messages to the email address.
 

4.7. The basis for the right to process data is the User's consent expressed in the form of clear active actions.

PayPerra reserves the right to:

1) Require the User to provide additional information disclosing the origin of digital assets and/or confirmation that these assets were not obtained illegally;

2) Block the account and any operations related to the User, transfer all available information and documents about the incident to financial regulatory and/or law enforcement authorities at the place of the Service's registration and, if necessary, at the Client's registration address;

3) Require the User to provide identity documents, video verification, registration address, solvency confirmation;

4) Return digital assets only to the details from which the transfer was made, after a full check by the Service's security service, if the legal origin of the Client's funds can be verified;

5) Refuse the User to withdraw funds to third-party accounts without explanation;
 

6) Withhold the User's funds until a full investigation of the incident is completed;

7) Monitor the entire transaction chain to identify suspicious transactions;

8) Refuse to provide the service to the User if the Service has reasonable suspicions about the legality of the origin of digital assets or if it is impossible to trace the entire chain of asset movement from the moment they appear, and withhold funds in special Service accounts.
 

Please note that transactions from exchanges under sanctions (for example CommEx, Garantex, Hydra market, Tornado cash, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, etc.) from any Iranian exchanges (for example Nobitex.ir, arzpaya.com) will be detained and frozen by the AML department.