AML / CTF Policy of the First-btc.io Service

1. General Provisions

1.1. The First-btc.io service applies measures to counter money laundering and terrorist financing (AML/CTF) in accordance with international standards, compliance principles, and partner platform requirements. 1.2. The purpose of this policy is to prevent illegal use of the service, protect bona fide users, and ensure transaction transparency. 1.3. As part of AML control, a Risk-Score assessment model is used, based on data from specialized blockchain AML analyzers.

2. Risk Assessment Model (Risk-Score)

2.1. Each incoming transaction undergoes mandatory AML analysis. 2.2. The following providers are used for analysis: Crystal Blockchain, Chainalysis, TRM Labs (depending on the asset network). 2.3. Based on the analysis results, a Risk-Score indicator is generated (risk level of the source of funds). 2.4. Risk-Score threshold values:

• up to 50% — acceptable risk level, the transaction is processed in standard mode;
• 50–69% — increased risk, additional information may be requested;
• 70% and above — the request is temporarily suspended for KYC and Source of Funds (SoF) procedures.

2.5. The presence of categories such as Sanctions, Terrorism Financing, Child Exploitation, Ransomware, Darknet Marketplace may result in blocking the request regardless of the overall risk percentage.

3. Verification Procedure (KYC / SoF)

3.1. In case of request suspension, the User is notified of the need to undergo verification. 3.2. Requested materials may include:

• identity document;
• selfie with the document;
• proof of source of funds (Source of Funds);
• screenshots of transaction history;
• sender contact details.

3.3. The verification period is up to 3 (three) business days from the moment a complete set of documents is provided.

4. Refusal to Pass KYC

4.1. The User has the right to refuse to undergo the verification procedure. 4.2. In case of refusal:

• the request is cancelled;
• funds are returned to the sender within 7–10 business days;
• only the actual network fee is deducted;
• additional deductions are allowed only for confirmed verification expenses, but not more than 5% of the amount and not more than 100 USD.

4.3. Indefinite retention of funds is not applied. 4.4. If there are legal grounds, official escalation to competent authorities is possible.

5. Possible Outcomes of an AML Case

1. Completion of the exchange;
2. Return of funds to the sender with confirmation of the return transaction;
3. Official transfer of information to competent authorities if there are legal grounds.

6. User Notification Before Payment (“Informed Choice”)

6.1. The User is provided with the opportunity to conduct an AML check of an address or transaction directly on the exchange website before making payment. 6.2. The check is performed using an integrated AML analyzer, based on which the Risk-Score is generated.

• A separate checkbox for active consent to the AML policy is placed on the request creation page;
• The User confirms passing the AML check or consciously refuses it, accepting the risks of possible transaction suspension.

7. Restrictions

• Transfers to third parties are prohibited;
• Use of anonymization services may result in blocking;
• The provided data must be accurate.

8. High-Risk Platforms

Funds associated with Garantex, Hydra, Bitzlato, Tornado, ChipMixer, and other high-risk services may be blocked.

9. Confidentiality

Information is transferred exclusively upon official request from competent authorities or if there are legal grounds.

10. Prohibited Jurisdictions

The service does not provide services to users from jurisdictions under international sanctions or with increased regulatory risk.