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AML / KYC policy

Draft. Requires review by a lawyer and a compliance consultant. Thresholds are a proposal; final values are approved by the owner.

1. Purpose

This policy describes how Draxma (draxma.io) prevents money laundering, terrorist financing, sanctions evasion and fraud. Operator — [SPECIFY legal entity]. AML officer — [SPECIFY position].

2. Whom we do not serve

  • persons on sanctions lists (UN, EU, OFAC, NSDC of Ukraine, [SPECIFY others]);
  • residents of FATF "increased monitoring / high-risk" jurisdictions and [SPECIFY list];
  • persons under 18;
  • transactions with funds from darknet markets, mixers, fraud and unlicensed gambling.

3. Wallet screening

Every USDT address we receive from or pay out to is screened:

  • always — against OFAC sanctions lists (updated daily), our own blacklist and the list of addresses frozen by Tether;
  • for large amounts — with a blockchain risk-analysis provider [SPECIFY provider]: the share of funds linked to sanctions, darknet, fraud, stolen funds, mixers, etc.

We do not accept a sanctioned payout address — an order with it cannot be created. If the sender address is high-risk, the order is held until clarified (AML hold).

4. Verification (KYC)

  • Level 0 — up to $1,000 per order and up to $3,000 in total over 30 days: email and the cardholder name matching the order.
  • Level 1 — above these amounts: photo of an identity document and a selfie with it.
  • Level 2 — on AML request or for large amounts: proof of source of funds (statement, contract, tax return, etc.).

We may ask you to confirm the sender card with a photo showing the first 6 and last 4 digits and the holder's name, with the rest covered.

5. Holds and refunds

If a transaction is suspicious, we:

  • ask in the order chat for source-of-funds documents, to be provided within 7 days;
  • hold the order during review — up to 30 days;
  • after review, complete the exchange or return the funds to your address. Refunds after an AML hold are subject to a 5% fee, capped at $100, covering screening and handling;
  • where required by law, notify the competent authority and hold funds at its request.

6. Data retention

Verification data and transaction history are kept for [SPECIFY, e.g. 5 years] after the last transaction. Access is limited to authorised staff.

7. Contact

[email protected] (placeholder).