Exchange rules

AML/KYC Policy
GroshX is a cryptocurrency exchange that takes the security of its customers and compliance with laws in the field of financial transactions seriously. GroshX believes that the protection of customer data and funds is of the highest priority, so it takes all possible measures to ensure maximum security.
One of the most important measures is compliance with AML (Anti-Money Laundering) and KYC (Know Your Customer) policies. These policies help to protect GroshX from possible use of the platform for financial crimes such as money laundering, terrorist financing, or other illegal transactions.
By using our cryptocurrency exchange service, you agree to the following terms and conditions:
You warrant that you are not a citizen of, and do not conduct transactions on behalf of, any of the following countries that are blacklisted or graylisted by the Financial Action Task Force (FATF) Afghanistan, American Samoa, the U.S. Virgin Islands, the territory of Guam, Iran, Libya, Libya, the State of Palestine, Puerto Rico, Somalia, the Democratic People's Republic of Korea, the Northern Mariana Islands, the United States, Syria, the Russian Federation, the Republic of Belarus, the Republic of Sudan, Transnistria, the temporarily occupied territories of Georgia, the Turkish Republic of Northern Cyprus, Western Sahara, the Federal Republic of Ambazonia, Kosovo, South Sudan, Canada, Nicaragua, Trinidad and Tobago, Venezuela, and the temporarily occupied territories of Ukraine;
  • You undertake to comply with all applicable laws and regulations in your country regarding cryptocurrency exchange;
  • Your funds used for cryptocurrency exchanges must be legally acquired, and you cannot use funds from illegal sources;
  • You agree to comply with our identity verification policies and procedures, including providing the necessary documents and information as required;
  • In the event of suspected illegal or fraudulent activity, we reserve the right to suspend transactions and report them to the appropriate authorities.
All transactions conducted through our service are subject to monitoring for compliance with regulatory requirements and security.
We recommend that you take additional security measures, such as using secure wallets, two-factor authentication, and software updates.
Payments from exchanges such as Garantex and Commex, as well as from the following services - Tornado Cash, Hydra, Blenderio, Lazarus Group, Genesis Market, ChipMixer, Shinbadio - are strictly prohibited. Transactions with these platforms will be immediately blocked.
If you have any questions or concerns regarding the use of our service, please contact our support team.
GroshX is also very interested in safe cryptocurrency trading. It conducts strict checks on each transaction to ensure that the funds used to buy or sell cryptocurrencies are not related to criminal activities. All transactions are subject to verification and analysis using advanced technologies, which allows GroshX to quickly identify and prevent possible financial crimes.
In the event of a violation of our AML and anti-fraud policy, we reserve the right to temporarily freeze your transaction for 30 days in order to conduct the necessary checks and investigations.
GroshX's Anti-Money Laundering, Anti-Terrorist Financing and Know Your Customer Policy (hereinafter referred to as the "AML/CFT Policy") is designed to prevent and mitigate the possible risks of GroshX's involvement in any illegal activity.
Money laundering is defined as:
  • Conversion or transfer of property derived from criminal activity or property received in lieu of such property, knowing that such property is derived from criminal activity or from an act of participation in such activity, with the aim of concealing or disguising the illegal origin of the property or facilitating any person involved in such activity to evade the legal consequences of the actions of that person;
  • Acquisition, possession or use of property derived from criminal activity or property received in lieu of such property, knowing at the time of receipt that such property was derived from criminal activity or from an act of participation in it;
  • Concealment or concealment of the true nature, source, location, disposal, movement, rights to or ownership of, property derived from criminal activity or property obtained in lieu of such property, knowing that such property is derived from criminal activity or from an act of participation in such activity.
Money laundering also means participating in, associating with, attempting to commit, and aiding, abetting, facilitating, assisting, and counseling in the commission of any of the above activities.
Terrorist financing is defined as the financing and support of a terrorist act and its commission, as well as the financing and support of travel for the purpose of terrorism.
Both international and local laws and regulations require GroshX to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and to take action in the event of any form of suspicious activity on the part of its Users.
AML/KYC Policy covers the following issues:
  • Internal control;
  • Compliance Officer;
  • Staff training;
  • Verification procedures;
  • Monitoring, risk assessment and risk-based approach;
  • AML/KYC audit programs.
  • Internal control
We have developed a structured system of internal controls to comply with applicable anti-money laundering and anti-terrorist financing ("AML/CFT") laws and regulations, including, but not limited to:
  • Identifying the customer and verifying the information provided;
  • Establishing a special regime for working with clients who are public figures (PEPs);
  • Detecting unusual activities and facilitating the reporting of suspicious activities; (SAR);
  • Maintaining customer documentation and transaction history.
Compliance Officer
The Compliance Officer is a person duly authorized by GroshX whose responsibility is to develop and ensure the effective implementation of AML/KYC. The Compliance Officer is obliged to report any violations of AML/KYC procedures and is responsible for collecting and filing SARs.
The Compliance Officer's responsibility is to oversee all aspects of GroshX's anti-money laundering and anti-terrorist financing measures, including but not limited to:
  • Establishing and updating internal policies and procedures for completing, reviewing, submitting and retaining all reports and records required by applicable laws and regulations;
  • Collecting User identification information and verifying the information provided; implementing a records management system for proper storage and retrieval of documents, files, forms, and logs;
  • Gathering and analyzing information relating to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing that have become apparent; investigating any unusual, suspicious activity;
  • Reporting to the relevant authorities in case of suspicion of money laundering or terrorist financing; providing information to law enforcement agencies in accordance with the requirements of applicable laws and regulations;
  • Periodic submission of written reports to the board on compliance with the requirements of the law;
  • Organization of employee training;
  • Fulfillment of other duties and obligations related to compliance with legal requirements;
  • Regularly update the risk assessment.
  • The Compliance Officer has the right to interact with law enforcement agencies involved in the prevention of money laundering, terrorist financing and other illegal activities.
Training
All employees receive full anti-money laundering and counter-terrorist financing training, as well as specific job-related guidance. Training is conducted at least once every twelve (12) months to ensure that trainees are informed and act in accordance with all applicable laws and regulations. Employees receive additional training as needed (if a new law or regulation is adopted, if required by law, etc.) New employees receive appropriate training before starting work. The training program is regularly updated to reflect applicable laws and regulations.
Verification procedures
GroshX establishes its own customer verification procedures within the framework of AML/KYC standards.
GroshX conducts legal due diligence and KYC checks before entering into business relations with a client, customer, or contractor.
During the due diligence and KYC process, as well as for opening an account, the identity, the identity information provided and the documents submitted must be checked against sanctions and watch lists, including the PEP list. GroshX uses special tools, a structured verification system and checks for this.
With regard to legal entities (their owners/shareholders/beneficiaries, etc.), GroshX conducts special enhanced due diligence, KYC, and compliance procedures.
GroshX provides a specific enhanced identification, KYC, due diligence, and compliance procedure for customers called PEPs, regardless of their place of residence.
Monitoring, risk assessment and risk-based approach
GroshX monitors customer transactions, assesses risks, and detects suspicious activity. For this purpose, a specially developed system is used, including the use of high-performance tools.
GroshX takes a risk-based approach to combating/preventing money laundering and/or terrorist financing.
To assist in determining the level of AML and CFT due diligence to be performed on a client, a compliance risk profile is calculated at the outset of the relationship (Low, Medium, High) and then regularly reviewed.
AML/KYC accordingly ensures that ongoing transaction monitoring is conducted to identify transactions that are unusual or suspicious compared to the customer profile.
The determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the client's knowledge (KYC), of his financial behavior and the counterparty to the transaction.
If a transaction is inconsistent with the customer's known personal routine activities or personal habits, the transaction may be considered suspicious. Data and transaction monitoring tools are used to identify unusual/unusual patterns of customer activity. After review and investigation, it is the decision of the Compliance Officer whether or not to file a SAR.
Once a SAR has been filed with the appropriate agency, a copy of the documentation is kept. The filing of a SAR is confidential and only GroshX employees involved in the investigation and reporting process will be aware of its existence.
All records are retained for at least (5) years and are available upon official request by an authorized examiner, regulator or law enforcement agency.
Any GroshX employee should inform the Compliance Officer of any atypical transactions they observe that they cannot attribute to a legitimate activity or source of income known to the customer.
AML audit
The Compliance Officer is responsible for conducting a money laundering and financial audit at least annually. Other audit requirements are set forth in internal policies and procedures.
We apply due diligence measures, among other things:
When establishing business relations;
When verifying information collected in the course of due diligence, or in case of doubts about the sufficiency or truthfulness of documents or data collected earlier when updating the relevant data;
On suspicion of money laundering or terrorist financing;
In certain other cases, including in other precise cases provided for by law and in cases of detection of "red flags" in accordance with internal procedures.
Saving data
We retain originals or copies of documents that serve as the basis for identification and verification of individuals and documents that serve as the basis for establishing business relationships for at least five years after the termination of business relationships.
We retain documents prepared in relation to a transaction in any medium, as well as documents and data that serve as the basis for reporting obligations, for at least five years after the transaction or fulfillment of the reporting obligation.
Our monitoring of business relationships includes, in particular:
  • Reviewing transactions performed in business relationships to ensure that the transactions are consistent with our knowledge of the client, their activities and risk profile;
  • Regularly updating relevant documents, data or information collected in the course of due diligence;
  • Identification of the source and origin of funds used in the transaction;
  • Paying greater attention to transactions that are likely to be related to money laundering or terrorist financing, including complex, high value and unusual transactions and transaction patterns that have no reasonable or apparent economic or legitimate purpose or that are not typical of the business;
  • Paying more attention to a business relationship or transaction whereby the customer (or the customer's payment provider, etc.) originates from a high-risk third country or a country or territory designated by law as a country or jurisdiction with a factor(s) that increases geographic risk.
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