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Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last Updated: May 30, 2026

ChangeCoinPay is committed to combating money laundering, terrorist financing, and other illicit financial activities. This AML/KYC Policy outlines our compliance measures and user obligations.

1. Policy Statement

ChangeCoinPay strictly prohibits the use of our Service for:

• Money laundering or terrorist financing
• Fraud, scams, or deceptive practices
• Sanctions evasion
• Trafficking of illegal goods or services
• Any activity that violates applicable laws

2. No-KYC Service Model

2.1 Standard Transactions

ChangeCoinPay operates as a no-KYC service for standard cryptocurrency exchanges, meaning:

• No account registration required
• No identity verification (ID, passport, selfie) for typical transactions
• No collection of personal information (name, address, email) unless voluntarily provided for support

2.2 When KYC May Be Required

We reserve the right to request identity verification in the following cases:

• High-Value Transactions: Exchanges exceeding $10,000 USD equivalent in a 24-hour period
• Suspicious Activity: Transactions exhibiting unusual patterns or red flags
• Law Enforcement Requests: Valid legal requests from authorities
• Sanctions Screening: Transactions involving addresses flagged by OFAC, UN, or EU sanctions lists

If KYC is requested, we will notify you via the transaction order page or contact information you provided.

3. Transaction Monitoring

3.1 Automated Screening

All transactions are subject to automated monitoring for:

• Sanctions Compliance: Wallet addresses are screened against OFAC, UN, and EU sanctions lists
• Risk Scoring: Transactions are risk-scored based on amount, frequency, and wallet history
• Suspicious Patterns: Unusual activity such as structuring (smurfing) or rapid exchanges

3.2 Red Flags

We monitor for indicators of suspicious activity, including but not limited to:

• Multiple small transactions designed to evade detection
• Rapid exchange of funds through multiple cryptocurrencies
• Wallet addresses linked to known illicit activities (darknet markets, ransomware, hacks)
• Transactions to/from high-risk jurisdictions
• Patterns consistent with mixing or tumbling services

4. Transaction Limits

To mitigate risk, we enforce the following limits:

• Per-Transaction Maximum: $50,000 USD equivalent (may vary by cryptocurrency)
• Daily Limit (per IP): $100,000 USD equivalent across all transactions
• Enhanced Monitoring: Transactions above $10,000 USD undergo additional review

Limits may be adjusted at our discretion based on risk assessment and regulatory requirements.

5. Prohibited Transactions

We explicitly prohibit exchanges involving:

• Funds derived from illegal activities (theft, hacking, fraud)
• Proceeds of ransomware attacks
• Terrorist financing or support for designated terrorist organizations
• Darknet market transactions
• Sanctions evasion
• Child exploitation material (CSAM) proceeds
• Human trafficking proceeds

6. Cooperation with Law Enforcement

ChangeCoinPay cooperates with law enforcement and regulatory authorities when legally obligated to do so, including:

• Responding to valid subpoenas, court orders, and search warrants
• Reporting Suspicious Activity Reports (SARs) to FinCEN (US) or equivalent authorities
• Freezing or seizing funds pursuant to lawful requests
• Providing transaction records and metadata when legally required

User Privacy: We will only disclose data when legally compelled. We do not proactively share user data for commercial purposes.

7. Geographic Restrictions

Our Service is NOT available to users in:

• United States of America (all states, due to complex state-by-state regulations)
• Sanctioned Countries: North Korea, Iran, Syria, Cuba, Crimea, Donetsk, Luhansk
• High-Risk Jurisdictions: Countries identified by FATF as non-cooperative (subject to change)

We use IP geolocation and blockchain analysis to enforce these restrictions. Attempts to circumvent geographic restrictions (e.g., via VPN) are prohibited.

8. Third-Party AML Compliance

We partner with ChangeNOW for exchange processing. ChangeNOW maintains its own AML/KYC program and may:

• Request additional verification for certain transactions
• Refuse or freeze transactions that violate their policies
• Report suspicious activity independently

ChangeNOW AML Policy: https://changenow.io/aml-kyc

9. Data Retention

For AML compliance, we retain the following data:

• Transaction Records: 5 years from transaction date (or longer if legally required)
• IP Addresses: 90 days (extended if under investigation)
• Suspicious Activity Reports: 7 years minimum
• KYC Documents (if collected): 7 years after account closure or last transaction

10. User Obligations

By using ChangeCoinPay, you agree to:

• Provide Accurate Information: If KYC is requested, you must provide truthful and accurate documentation
• Not Use Stolen Funds: Ensure all cryptocurrency you exchange is legally obtained
• Comply with Local Laws: Abide by your jurisdiction's laws regarding cryptocurrency use
• Report Suspicious Activity: If you encounter suspicious transactions or scams, report them to [email protected]

11. Risk Assessment

We conduct ongoing risk assessments of our Service to identify emerging threats, including:

• New typologies of money laundering (e.g., DeFi exploits, NFT wash trading)
• Emerging high-risk cryptocurrencies or blockchain networks
• Regulatory changes in key jurisdictions
• Partnerships with third-party risk intelligence providers

12. Staff Training

Our team undergoes regular AML training to:

• Recognize red flags of suspicious activity
• Understand evolving AML regulations
• Properly handle law enforcement requests
• Protect user privacy while maintaining compliance

13. Transparency Report

We publish an annual transparency report detailing:

• Number of law enforcement requests received and honored
• Number of SARs filed (without compromising investigations)
• Number of transactions frozen or refused
• Aggregate statistics on transaction monitoring

Transparency reports are published at: https://changecoinpay.com/transparency (coming soon)

14. Updates to This Policy

We may update this AML/KYC Policy to reflect:

• Changes in applicable laws and regulations
• Evolving best practices in the cryptocurrency industry
• New threat intelligence or risk factors

Material changes will be announced with 30 days' notice. Continued use of the Service after changes constitutes acceptance of the updated policy.

15. Contact Information

For AML/KYC inquiries or to report suspicious activity:

• Compliance Email: [email protected]
• General Support: [email protected]
• Telegram: @changecoinpay_bot
• Hours: 24/7

ChangeCoinPay
Instant No-KYC Cryptocurrency Exchange
changecoinpay.com