AML
AML
(anti-money laundering policy)

Effective Date: 11/01. 2021.
Updated 05/27/2022.
This AML Policy (hereinafter referred to as the Policy) governs the activities of Bro.exchange in relation to the fight against money laundering and its involvement in the fight against money laundering and the financing of terrorist activities.

Terms and definitions

Money laundering is the legalization of the possession, use or disposal of money or other property obtained as a result of a crime. Bro.exchange strictly follows laws that prohibit us or any of our employees from knowingly engaging in or attempting to engage in any type of activity that is in any way related to money laundering. Our anti-money laundering policy is aimed at improving the security of customers and the services provided by the Service.
Terrorism Financing – the intentional provision or collection by any means, directly or indirectly, of funds with the intent to use those funds or on the condition that they be used to commit acts of terrorism.

2. Measures taken in compliance with the AML Policy

Bro.exchange service administration, understanding public danger of crimes related to money laundering and terrorist financing, has developed a set of organizational and legal measures in order to comply with the provisions of national legislation, as well as the requirements of the intergovernmental organization FATF.
The European regulation of AML is based on a number of legislative directives. Namely, the EU issued the Sixth Anti-Money Laundering Directive (6AMLD), which came into force on December 02, 2018.
Other legislative acts aimed at combating the legalization of proceeds from crime and the financing of terrorism are the following acts:

• 5th AML Directive ((EU) 2018/843);
• Proceeds of Crime Act 2002;
• Terrorism Acts 2000 and 2001;
• Anti-Terrorism Act 2008;
• Treasury Sanction Notices;

1. Know your customer – Know your customer. Mandatory identification of Users who are allowed to make transactions on our Service. To verify the User, the Administration has the right to require the following data to be provided:
   take a photo (“selfie”) with a citizen’s identity document: a scanned copy of the front and back of an official photo ID, i.e. a valid passport, driver’s license or other national ID;
   Proof of Residence: An official document issued within the last 3 months, clearly indicating the name and address of the client provided during registration on the Bro.exchange website. This could be a utility bill (for water, electricity, or a landline phone) or a bank statement. The copy must inсlude: full name, full address of residence, date of issue (within the last 3 months), name of the issuing authority, with official logo or seal;
   provide a copy of the front and back sides of the bank card and / or a photo of your bank card taken against the background of the main page of the Service (showcase with services). For privacy and security, only the last 4 digits of your credit card should be visible. It is allowed to hide 3 numbers on the back of the card (CVV code).
   The administration of the Bro.exchange service will take steps to confirm the authenticity of the documents and information provided by the Users. Identification information will also be verified using secondary sources, and the Service Administration reserves the right to continue investigating cases in order to obtain full confidence in the authenticity of the documentation provided.
   The administration of the Bro.exchange service reserves the right to monitor the User’s data on an ongoing basis, especially in cases where his identification information has been changed or his activity seemed suspicious (unusual for a particular User). In addition, the Administration reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.
2. Constantly monitoring operations passing through Service. We exercise constant control over all applications created on the Bro.exchange website. The administration of the service notifies Users of the ban on the implementation of exchange transactions from third parties using their account.
3. Assign Responsible Person (MLRO – Money Laundering Reporting Officer) exercising control and supervision powers for the implementation of the provisions of this Policy.
4. Risk Based Approach (RBA) — Risk-Based Approach). We implement different levels of verification, depending on the volume and number of transactions performed by the User.
5. Improve the professional skills and knowledge of team members Bro.exchange in terms of compliance with the requirements of the Policy.
6. Interacting with government agencies as required by law cases. In the event of a formal request from law enforcement or judicial authorities, we will be required to provide them with the requested information. Also, the Service Administration has the right to provide the data requested by official representatives of payment systems.
7. Improve Bro. exchange. We care about the reliability and security of your transactions. In this regard, we are constantly improving our IT department, whose main task is to protect the site from unauthorized access by intruders.
8. Bro.exchange service administration, in in cases prescribed by law, may require a regulatory requirement to verify the source of fiat money and/or cryptocurrencies to ensure that the sources of Funds used by the Client for the exchange are legal. As a document confirming the origin of the Funds, it can be a bank statement for fiat money or a video showing the details of a cryptocurrency wallet transaction.
9. In accordance with this Policy, the Service Administration , would be:
   —monitor all transactions. Administration reserves the right to ensure that reports of suspicious nature of transactions are reported to the appropriate law enforcement agencies through the Responsible Official;
   — request from the User any additional information and documents in case of suspicious transactions, also at the request of the regulator (The regulator can be an exchange, a government agency or other organization that has the appropriate legal grounds.);
   —suspend or terminate the User’s account if there is a reasonable suspicion that such User is involved in illegal activities.
10. However, the above list is not exhaustive , and the Responsible Officer will monitor Users’ transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or should be treated as bona fide.
11. Residence Country. This Policy sets out our risk criteria for AML/CTF. To reduce this risk, the Bro.exchange service administration does not accept clients who live in the following countries with an increased risk criterion:

Sources used for categorization:< /p>

• Transparency International;
• Know Your Country;
• FATF High Risk Jurisdiction List;
• List of high risk EU jurisdictions;
• Countries where digital assets are banned or have trade restrictions;
• Countries where digital assets are not prohibited;
• Countries subject to UN Security Council sanctions.
• All customers residing in the countries listed below are prohibited from serving on the Mine.exchange service and cannot be accepted as Users.
• Any customers from these countries will be denied service and any funds will be returned to the source.
• Full list of prohibited jurisdictions:

USA
Afghanistan
Albania
Angola
Algeria
Bangladesh
Barbados
Bolivia
Botswana
Burma (Myanmar)</span >
Burundi
Cambodia
Central African Republic</span >
Chad
Congo
Conakry
Ivory Coast
Krym (Ukraine)</span >
Cube
Democratic People’s Republic of Korea (DPRK )
Ecuador
Egypt
Equatorial Guinea< br style=”margin: 0px; padding: 0px;” />Eritrea
Ghana
Guinea-Bissau
Haiti
Guyana
Iran
Iraq
Lao People’s Democratic Republic
Lebanon
Libya
Mali
Morocco
Myanmar
Nepal
Nicaragua
North Macedonia< br style=”margin: 0px; padding: 0px;” />Pakistan
Panama
Qatar
Saudi Arabia< br style=”margin: 0px; padding: 0px;” />Somalia
South Sudan< br style=”margin: 0px; padding: 0px;” />Sudan
Syria
Tunisia
Uganda
Vanuatu
Venezuela
Yemen
Zimbabwe
Jamaica

Bro.exchange service administration is also not accepts clients from disputed territories as they do not provide commonly recognized official documents, including:
Donetsk People’s Republic (DPR) / Lugansk People’s Republic (LPR)
Transnistrian Moldavian Republic
Nagorno-Karabakh Republic</span >
Republic of Abkhazia< br style=”margin: 0px; padding: 0px;” />Republic of Somaliland< br style=”margin: 0px; padding: 0px;” />Republic of South Ossetia
Turkish Republic of Northern Cyprus</span >
Republic of China (Taiwan)
Passports issued by the Russian Federation in Crimea , and passports issued to residents of Donetsk and Lugansk regions of Ukraine are not subject to verification
Republic of Kosovo< br style=”margin: 0px; padding: 0px;” />Saharan Arab Democratic Republic</span >
Republic of Artsakh< /p>

Funds transferred from the following platforms will be blocked.

Red Risk Platforms:

Black Sprut

Wasabi Wallet

Bitzlato

Hydra

Garantex

Tornado Cash

OMG!OMG!

MEGA DARKNET MARKET

FreeBitcoin
Casino
Gambling
1xBet

Please note that any transactions with a risk higher than 60% will be blocked!

< strong>KYT Policy
(Know Your Transaction)< /strong>

Effective Date: 11/01. 2021.
Updated 05/27/2022.
The KYT (Know Your Transaction) policy is aimed at identifying the client of the transaction in the event of a precedent when the Service has reasonable suspicion that the Client is using Bro.exchange for other purposes.

suspects the Client of illegal actions that can be qualified as laundering or attempted laundering of digital assets obtained by illegal means or funds of overtly criminal origin.For these purposes, the Service has the right to use any legal information, third-party tools for analyzing the origin of digital assets, as well as its own developments of the screening systеm.

In this case Bro.exchange Service reserves the full right to:

1. Require Client to provide additional information, disclosing the origin of digital assets and/or confirming that these assets were not obtained by criminal means;
2. Lock your account and any related operations with the Client, transfer to the controlling financial activities and/or law enforcement agencies at the place of registration of the Service and, if necessary, at the address of the Client’s registration, all information and documents available on the incident;
3. Require identity documents from the Client , physical existence, registration address, solvency;
4. Revert digital assets to props only from which the transfer was made or go to other details, after a full check by the security service of the Service, if it was possible to verify the legal origin of the Client’s funds;
5. Refuse the Client to withdraw funds to the account third parties without explanation;
6. Hold Client funds until the incident is fully investigated ;
7. The Service reserves the right to control all chain of transactions in order to detect suspicious transactions;
8. The Service reserves the right to refuse the Client in the provision of the service, if the Service has reasonable suspicions of the legitimacy of the origin of digital assets and hold funds in special accounts of the Service;
9. The Service reserves the right to refuse the Client in the provision of the service, if the Service has reasonable suspicions about the legitimacy of the origin of digital assets and hold funds on special accounts of the Service, if it is impossible to track the entire chain of movement of digital assets from the moment they appear.

Conditions for Refunding Stopped Checks based on the results of AML analysis of the transaction:

Refunds are subject to full review by the service the security of the Service, which may inсlude detailed verification of the sender. Refunds are made minus a commission of up to 5% of the transaction amount to cover the labor costs for processing the application and organizing the refund.
The return, subject to approval by the Service, will be processed by the Service within 7 (seven) calendar days, starting from the date when the User was notified with the decision of the Service regarding his return request.
When making a refund, after passing the check (verification), the user must confirm the details to receive a refund.