AML / KYC / SoF Policy

1Risk-based AML control model (Risk Score)

Each incoming and outgoing transaction is assigned a Risk Score based on blockchain analysis, AML/KYT results and source-of-funds categorisation (Risk Labels).

The Risk Score is computed from a combination of factors including transaction structure, source of funds, behavioural signals, transaction links and data from analytical and infrastructure services used by TrustEx.best.

Risk levels

Suspension threshold is set at Risk Score ≥ 70.

In certain cases an operation may be temporarily suspended at risk levels 20–69 (medium) when transaction shows additional high-risk signals, including but not limited to:

• sanctions exposure — from 0.1%;
• links to darknet and fraud services — from 0.5–1%;
• use of mixers and anonymisation services — from 3–5%;
• tainted funds — from 5–10%;
• indirect links to high-risk addresses — from 15–20%;
• participation in illegal or unregulated services — from 1–5%;
• abnormal transaction activity or limit-circumvention attempts;
• inability to confirm source of funds (SoF);
• user refusal to pass KYC/verification;
• data inconsistencies;
• geographic and jurisdictional risks;
• matches with internal risk databases;
• AML system signals and additional analysis results.

Source of funds categories (Risk Labels)

Even minor exposure to critical-risk categories may suspend the operation regardless of overall Risk Score.

Final decision is based on combination of risk factors, not a single metric.

TrustEx.best may suspend the operation, request KYC and/or SoF until full resolution.

2Analytical technologies and tools

For analysing the origin of cryptocurrency funds, evaluating transaction links and detecting high-risk operations, TrustEx.best uses a combination of analytical, technical and infrastructure solutions.

In particular, TrustEx.best uses the GetBlock infrastructure to retrieve and process blockchain data needed for transaction, address and network activity analysis.

Additionally, internal and external analysis methods may be used to assess the risk of a specific operation, address, transaction chain or source of funds. Tools used can detect links to:

TrustEx.best reserves the right not to disclose the full list of tools and internal criteria if such disclosure may reduce the effectiveness of AML/KYC/SoF procedures or create circumvention risk.

• sanctions lists and sanctioned jurisdictions;
• darknet markets and related services;
• fraud / scam services and schemes;
• stolen funds;
• mixers and anonymisation services;
• unlicensed or high-risk services;
• wallets, addresses and platforms hiding the origin of funds;
• other AML high-risk sources.

3KYC and Source-of-Funds (SoF) verification

When Risk Score ≥ 70 or other elevated factors are detected, the user may be requested documents and information to pass KYC and/or SoF verification, including:

Verification time depends on case complexity, completeness of data and detected risks. Estimated timing:

• passport or ID card;
• selfie with the document;
• proof of residence (if required);
• Source of Funds confirmation;
• transaction history screenshots;
• explanation of the operation's economic purpose;
• other documents if needed.

• KYC — up to 24 hours;
• AML / SoF — from 72 hours to 10 business days.

Failure to provide documents, refusal of verification or knowingly false information may result in service refusal, suspension and refund decision under this Policy.

4Video verification

In high-risk cases TrustEx.best may initiate video verification as an additional measure for confirming user identity, legality of funds and actual control over wallets/payment instruments. Within video verification the user may be required to:

TrustEx.best never requests passwords, seed phrases, private keys or any data granting direct access to user funds.

• state full name;
• state the current date;
• show an identity document;
• confirm purpose and nature of the operation;
• explain the origin of funds;
• show transaction history or other supporting evidence if needed.

5AML refunds

If exchange cannot be completed, the user refuses verification, source of funds cannot be confirmed or other circumstances prevent completion, TrustEx.best may initiate a refund to the sender per this Policy and internal security procedures.

Refunds are processed after the necessary verification, provided refund does not contradict applicable law, AML/CTF rules and internal security requirements.

A refund is only possible once the user provides the data and documents required under the AML / KYC / SoF procedures (including, where necessary, identity documents, proof of ownership of the sending address or account, and proof of source of funds). Without such information, or where the user refuses to provide it, a refund may not be possible or may be delayed until the required information is obtained.

AML refund fee may be up to 5% of the amount but not more than 100 USD, plus actual network fees, payment provider fees and other mandatory refund-processing costs.

6Source-of-funds restrictions

TrustEx.best does not accept funds with high or critical risk per AML/KYT analysis. Such operations are suspended pending additional verification including KYC and/or SoF.

Prohibited and high-risk sources include but are not limited to:

The list is non-exhaustive and may be updated based on blockchain analysis, internal risk criteria and data from infrastructure used by TrustEx.best including GetBlock.

• sanctioned addresses and jurisdictions on international sanctions lists;
• anonymisation/mixing services (incl. Tornado Cash, Blender.io and similar);
• darknet markets and related services;
• sources linked to fraud, stolen funds, extortion and other illegal activity;
• platforms with high risk or no proper KYC procedures;
• sources aimed at hiding origin of assets or circumventing AML/CTF.

TrustEx.best is not liable for funds from such sources and reserves the right to act per applicable law and AML/CTF requirements.

Prohibited and high-risk platforms (non-exhaustive)

Funds originating from the marketplaces, bots, mixers, exchange and payment services listed below are not accepted. On detection the operation is suspended, AML/KYC is initiated, and funds may be returned to the sender minus fees and penalties as set out in this Policy.

Darknet markets and related services

HydraBlack SprutMEGA Darknet MarketOMG!OMG!SolarisKraken MarketRuTORWayAwayMatangaRAMPDarknetoneAlphaBayDream MarketEmpire MarketGenesis MarketWall Street MarketSilk RoadBlackBankVersus MarketWhite House Market

Mixers and anonymisation services

Tornado CashBlender.ioChipMixerSinbad.ioBitcoin FogHelixBestMixerCryptoMixerSmartMixerWasabi WalletSamourai / WhirlpoolCoinJoin servicesMixeroAnonyMixerYoMix

Sanctioned / shut-down / Russian exchanges

GarantexRapira.netHTX (formerly Huobi)CommexBTC-eWEX ExchangeBitzlatoLazarus GroupSuexCashbankChatexYobit.netEXMO.comEXMO.meNobitex.irOKX (RU accounts)Bybit (RU accounts)

High-risk exchangers and P2P platforms

NetEx24.netTrocador.appAnonexch.ioAifory.proterminal.cashSkyCrypto.netFlashObmen.com60cek.nethd-change.comCoinBlinker.comMetka.ccAlfaBit.orgmeer.kgBitBitsBixterMagnetic Exchange (shadow flows)Bitpapa (no KYC)LocalBitcoins-clones without KYCxRocket.tgArvix.pro (abcex.io)ProstocashCoinStartKassa.cc

High-risk merchants and payment gateways

CryptomusCrypto CloudCriptaNowPayments (shadow)Plisio (shadow)CoinPayments (shadow)OxaPayCoinsPaid (shadow)Heleket.com

Prohibited payment systems

payeer.comWebMoneyFreeKassaNixMoneyVexelFunPayPerfect Money (shadow)AdvCash (RU)Capitalist (RU)YooMoney (Yandex.Money)QIWI (closed)

Gambling and betting

1xBet1xBitStakeRoobetDuelBitsDuckDiceBC.GamePrimediceDoublewayFortuneJackBetFuryCloudbetBovadaTrueFlipCryptoGamesSportsbet.ioVavadaPin-UpMostbet

Scam / fraud / fake services

HYIP projects of any natureFinancial pyramidsFake exchanges / clonesCryptolocker / Ransomware walletsUnlicensed asset managementSignal / pump-and-dump groupsFake-ICO wallets

Risk Categories

SanctionsTerrorism FinancingDarknetRansomware / MalwareMixing ServicesChild AbuseStolen FundsScam / FraudProtocol PrivacyBridgeDecentralized Exchange (DEX)Gambling

7Pre-AML check

The user may perform their own pre-AML check before sending using third-party services, including BestChange monitoring service.

Check via: https://www.bestchange.pro/report/

Pre-check results may be provided to TrustEx.best support for additional review and comparison with the internal Risk Score model.

Third-party pre-check results are auxiliary and do not automatically confirm or reject the operation; the final decision is taken by the service based on combined risk factors.

8Operation suspension

TrustEx.best may temporarily suspend an operation upon detection of elevated AML risk, suspicious factors, need for additional verification or incomplete user data.

Funds may be held during verification, normally not more than 10 business days, unless a different timeframe is required by case nature, complexity, awaited user response or legal requirements.

9Cooperation with regulators

On detection of illegal activity, suspicious transactions, possible terrorism financing, sanctions violations or other significant risks, TrustEx.best may share information with competent authorities and financial regulators per applicable law.

10Use of payment instruments

The user must use only their own payment instruments, wallets, accounts and details, unless explicitly agreed otherwise.

Using third-party accounts/cards/wallets may be considered a high-risk factor and result in suspension, additional document requests or service refusal.

11Additional verification

TrustEx.best may request additional documents/information for AML/KYC/SoF verification when needed for risk assessment, source-of-funds confirmation, identity verification or operation legality.

Reasons may not be fully disclosed if disclosure could affect AML procedure effectiveness, create circumvention risk or contradict security requirements.

12Right to refuse service

TrustEx.best may refuse to perform an operation in case of elevated AML risk, failure to provide requested data, inability to confirm source of funds, false information or other circumstances indicating elevated risk.

In such case the operation may be cancelled and funds returned to sender minus network fees, payment provider fees and other mandatory costs, if such refund is permitted under this Policy and applicable law.

13Refusal to undergo AML/KYC verification

If the User refuses to undergo the AML/KYC verification or fails to provide the requested documents and/or information required to complete the verification, the Service is entitled to hold the received crypto assets for up to 60 (sixty) calendar days from the moment of their receipt in order to carry out the necessary checks and comply with AML/CFT requirements.

Upon expiry of this period, in the absence of successful verification, the crypto assets shall be returned solely to the wallet address from which they were originally sent, less blockchain network fees and other costs associated with processing the return.

14Personal data processing

User personal data is transmitted via secured channels and used solely for AML/KYC/SoF procedures, legal compliance, operation security and fraud prevention.

By providing documents and information under this Policy, the user consents to their processing to the extent necessary for these purposes.

15Final provisions

TrustEx.best may update this Policy without prior notice when needed for legal compliance, security improvement or update of internal control procedures.

Use of the service implies user consent to this AML / KYC / SoF Policy.

Last updated: 2026.

Last updated: 2026