The service uses a risk assessment systеm and AML analytical tools to detect suspicious activity.

Paspar.net reserves the right to apply AML/KYC procedures to specific users, addresses, and particular crypto-asset transactions based on internal policy. The service does not enter into business relationships with any individual or legal entity suspected of money laundering or associated with illegal sources of funds.

Preliminary AML Check and User Consent

Users have the option to conduct a preliminary AML check of their address or transaction prior to exchanging funds using dedicated AML analysis tools, including but not limited to BestChange.

Based on the results of the preliminary check, the user may submit the results to the operator for exchange risk assessment. The user also has the right to knowingly decline the preliminary check by confirming their consent to assume the associated risks — by confirming the corresponding notification during the order process.

The preliminary check may be a paid service provided by AML analysis platforms and is paid for by the user independently.

AML Analyzer and Risk Score Model

Transaction verification is carried out by AML officers using analytical tools (Crystal Blockchain, Chainalysis, Elliptic) and risk labels that allow the origin of funds and the level of risk to be determined.

The Risk Score typically represents a distribution of fund shares across various risk categories. Each category indicates what portion of the funds is associated with a particular type of source.

Risk Classification

All transactions are classified according to three risk levels:

• Very High Risk
• High Risk
• Medium Risk

Depending on the risk level, the service decides whether to accept the transaction, suspend it, conduct additional verification, or return the funds.

Risk Levels and Processing Procedures

Very High Risk

If any share of risk (>0%) is detected in any of the listed categories, the transaction is automatically considered critical and placed under enhanced review.

Service actions:

• Suspends transaction processing.
• Sends the user a request to provide data and confirm the origin of funds.
• The transaction is placed under AML review status.

The user is given up to 7 business days to provide documents and/or explanations.

Refund procedure:

If within 7 business days the documents are not provided or do not confirm the origin of funds, the transaction is placed under a hold status for up to 30 business days for additional compliance review. Upon completion of that period, the following outcomes are possible:

• Return of funds to the sender’s original address (within 1 business day of the refund decision).
• Referral of information to competent authorities if signs of unlawful activity are identified.

High Risk

If the risk share in any of the listed categories exceeds >1%, the transaction is considered elevated-risk. The risk of each category is not cumulative — multiple labels may be present, each not exceeding 1%.

Service actions:

• Suspends the transaction.
• Requests confirmation of the origin of funds from the user.
• Conducts an additional AML review.

The user is given up to 7 business days to provide documents or explanations.

Refund procedure:

• If within 7 business days the documents are not provided or do not confirm the origin of funds, the service may hold the funds for up to 30 business days to complete the review, after which the funds are returned to the sender’s address (within 1 business day of the final decision).
• If signs of unlawful activity are identified during the review, the case may be escalated for compliance investigation.
• If the user successfully provides the requested documents and confirms the legitimacy of the funds, the service returns the funds to the original address within 1 business day (or completes the exchange, at the service’s discretion).

Medium Risk

The Medium Risk category includes transactions that do not contain critical or elevated AML labels and fall within acceptable risk thresholds.

If the values for the listed categories do not exceed the established thresholds, the transaction is processed in standard mode. In standard cases, Medium Risk transactions are processed without any hold or additional review.

Refund procedure:

If a transaction is deemed undesirable, the service cancels the processing of the operation and returns the funds to the sender’s address within 1 business day of the decision.

AML and KYC/SoF Procedure

The AML/KYC procedure applies to transactions identified by the systеm as suspicious. The service contacts the user to request the necessary documents.

Verification Stages

Required Documents for KYC (Identity Verification)

• A high-quality photograph or scan of a valid identity document (passport, ID card, driver’s licence);
• A selfie of the user holding their identity document alongside a handwritten note with the current date and the name of the service;
• Proof of residential address (bank statement, utility bill, or other document issued no more than 3 months ago).

Required Documents for SoF (Source of Funds Verification)

• A screenshot or statement from a wallet/exchange confirming ownership of the sending address;
• Transaction history demonstrating the source of incoming funds;
• An explanatory note on the origin of the crypto assets (purchase on an exchange, mining, salary, sale of property, etc.);
• Any additional documents confirming the legitimate origin of the funds.

Refund Fee for AML Cases

Standard Refund Fee

When returning funds following an AML review, the service may charge a fee of up to 3% of the blocked amount, but not exceeding $50 equivalent at the time of the operation. This fee covers the costs of AML analysis, compliance review, and operational expenses.

Fee for Good-Faith Clients

If the user has successfully completed the KYC/SoF procedure and the review finds no evidence that their funds are connected to money laundering or any other unlawful activity, the refund fee is limited exclusively to the blockchain network fee (network fee) required to process the return transaction. No additional charges are applied in this case.

Maximum Fund Hold Periods

Holding a user’s funds for an indefinite period is not permitted. For each AML case, the service undertakes to ensure one of the following outcomes:

Return of funds to the sender:

• If the user provided documents and the review found no connection to unlawful activity — the refund is processed within 1 business day of the decision.
• If the user did not provide documents within 7 business days — the funds are held for no more than 30 business days, after which they are returned to the sender’s original address with confirmation provided (transaction hash).

Official escalation:

If signs of unlawful activity are identified during the review (money laundering, terrorist financing, fraud, etc.), the service refers the information to financial intelligence units, law enforcement agencies, or other competent authorities. In this case, the funds remain blocked until a decision is received from the competent authority.

Other forms of fund retention not covered by the above outcomes are not permitted.

Personal Data Protection and Processing

Paspar.net guarantees the secure and proper collection, encryption, and storage of users’ personal data in strict compliance with international standards (GDPR). Access to the data is restricted exclusively to authorised AML officers. Detailed information on data processing and protection methods is set out in our Privacy Policy.

Sanctions and PEP Screening

Users are screened against international sanctions lists (OFAC, EU, UN, UK, and other internationally recognised sources). Additional checks may be applied to politically exposed persons (PEP) and their associates.

The service prohibits any activity associated with platforms or services that facilitate anonymous, non-transparent, or illegal transactions, including mixing services, anonymous platforms, and services from sanctioned jurisdictions.

Service’s Right to Conduct Verification

The service reserves the right to:

• Conduct AML checks on any transactions;
• Request additional information from users;
• Temporarily hold funds during the review;
• Act in accordance with applicable legal requirements and internal compliance procedures;
• Refuse service if the user declines to provide the requested documents or if there are grounds to believe that the transaction is intended for money laundering.

User Responsibilities

The user undertakes to:

• Not use the platform for unlawful purposes;
• Not conduct transactions through prohibited services;
• Provide accurate information when undergoing the KYC/SoF procedure.

By using the service, the user agrees to this AML control policy.