GetBit AML/CFT Policy (Anti-Money Laundering & Counter-Terrorist Financing Policy)

Effective date: 02.08.2023

Updated: 28.01.2026

1. General provisions

1.1. This AML/CFT Policy (hereinafter, the Policy) defines the measures applied by the GetBit service to counter the legalisation (laundering) of proceeds of crime and the financing of terrorism.

1.2. The Policy is an internal regulation of GetBit and is binding on all staff involved in processing orders and carrying out operations.

1.3. The Policy has been developed in line with the Risk-Based Approach, the FATF Recommendations, the requirements of monitoring services and applicable law.

1.4. By using the GetBit service, the user agrees to this Policy.

2. Terms and definitions

2.1. GetBit is the trade name of a digital asset exchange service.

2.2. The Service is the GetBit information system designed to provide digital asset exchange services.

2.3. User means an individual who uses the services of GetBit.

2.4. Digital assets mean cryptocurrencies and other digital currencies based on blockchain technology.

2.5. AML check means an automated check of an address or transaction using AML analysers.

2.6. Risk Score is the final aggregated numerical indicator of a transaction's risk level.

2.7. KYT (Know Your Transaction) is the procedure for monitoring and analysing a transaction.

2.8. SoF (Source of Funds) is the procedure for confirming the source of funds.

2.9. KYC (Know Your Customer) is the procedure for identifying the user.

2.10. MLRO is the officer responsible for AML/CFT matters.

3. Organisation of AML control

3.1. The AML, KYT, SoF and KYC functions are performed by the internal GetBit Security Department.

3.2. The Security Department is responsible for analysing AML reports and Risk Scores, communicating with users, recording and documenting all cases, and making decisions on operations.

4. AML analysis and providers

4.1. All incoming transactions undergo a mandatory KYT check using an AML analyser.

4.2. GetBit does not adjust the Risk Score manually and does not use alternative risk assessment models.

4.3. The final Risk Score is the main and decisive risk assessment criterion. Risk labels are taken into account as part of the overall assessment and are not applied in isolation.

4.4. How the overall Risk Score is formed

4.4.1. The overall Risk Score is calculated by the AML provider used, within a risk-based transaction assessment model.

4.4.2. The Risk Score is an aggregated numerical indicator calculated from a combined analysis of the transaction parameters and the related risk factors.

4.4.3. The Risk Score may take into account, among other things:

– the movement history of the digital assets and their on-chain origin;

– the presence and share of risk labels (including but not limited to Scam, Dark Market, Enforcement Actions and similar categories);

– the nature, structure and sequence of transactions;

– behavioural and timing patterns in the movement of funds;

– other parameters used by the AML provider within its risk assessment model.

4.4.4. Risk labels are not applied in isolation and are taken into account solely as elements of the overall risk assessment expressed in the final Risk Score.

4.4.5. GetBit has no influence on the Risk Score methodology, does not adjust the score manually and uses the result in the form provided by the AML provider.

4.4.6. The final Risk Score is used to determine the permissible scenario for processing the transaction in accordance with this Policy.

5. Preliminary AML check

5.1. Before creating an order, the user can carry out a preliminary AML check of a cryptocurrency address on their own.

5.2. The preliminary AML check is available in the site header under "Check wallet" and leads to the AML check page of the BestChange monitoring service:

https://bestchange.biz/wiki/aml-faq

5.3. The user may carry out a preliminary AML check for a fee using valid AML analysers, including tools provided by the BestChange monitoring service or third-party AML services.

5.4. Based on the results of the preliminary AML check, the user is given an informed choice:

— to share the AML check results with the service operator for a preliminary assessment of whether the exchange can be carried out;

— or not to share the results, confirming their acceptance of the possible risks, including the risk that the transaction may later be suspended as part of the KYT check.

6. KYT, SoF and KYC procedures

6.1. The KYT procedure is applied by default to all incoming transactions; it is used to obtain the Risk Score and to decide whether additional control measures are needed.

6.2. Additional control procedures may be applied when the Risk Score exceeds 60%, when the share of risk labels is high, when no explanation of the origin of funds is given, when anonymous communication channels are used, and in the presence of other factors of increased regulatory or legal risk.

6.3. The SoF procedure is applied first and is aimed at confirming the origin of funds without identifying the user.

6.4. As part of SoF, the user may be asked for explanations, transaction hashes, links, statements, screenshots and other materials that relate to the origin of funds and do not contain personal data.

6.5. If sufficient and consistent explanations are provided, the KYC procedure is not applied.

6.6. The KYC procedure is applied only when the source of funds cannot be confirmed through SoF or when the overall level of risk requires the user to be identified.

6.7. GetBit does not request an arbitrary list of information. Every request relates to a specific KYT, SoF or KYC procedure, is limited to the purposes of risk assessment and is proportionate.

6.8. AML control sequence when the Risk Score threshold is exceeded

If, following the KYT check, the overall Risk Score exceeds 60%, the following sequence of actions applies:

the transaction is temporarily suspended;
the user is asked for explanations and materials under the SoF procedure;
if the origin of funds cannot be confirmed under SoF, the KYC procedure may be requested;

As part of the KYC procedure, the Service may request one or more of the following documents and materials from the User, depending on the level of risk, the nature of the transaction and the results of the preliminary check:

6.9. Documents and materials requested under the KYC procedure

If the KYC procedure is applied, the Service may request the following documents and materials from the User (depending on the nature of the risk and the specifics of the case):

— an identity document;

— a photo or video of the User holding the identity document and a sheet of paper showing the order number and/or the current date;

— a video confirming possession of the document and that the operation is being carried out knowingly, with a verbal confirmation that the corresponding order was created;

— an explanation of the origin of funds (Source of Funds);

— documents confirming the source of income or the nature of professional/business activity (if necessary);

— additional materials that objectively confirm that the funds belong to the User and are of lawful origin (including statements, screenshots, transaction confirmations and other relevant documents).

The specific list of documents is requested on the principles of sufficiency, proportionality and the risk-based approach. GetBit does not request excessive information and limits itself to the materials needed to assess risk and meet AML/CFT requirements.

6.10. The KYC procedure takes up to 7 (seven) business days from the moment the Operator receives a complete and correct set of the requested documents and information from the User. If the User provides incomplete or contradictory materials, or materials that need clarification, the review period may be extended until sufficient information is received; the User is notified of this separately.

7. Suspension of transactions and holding of funds

7.1. If the Risk Score exceeds 60%, GetBit may suspend processing of the transaction until the checks are completed.

8. Refunds and fees

8.1. Following the AML check, GetBit may carry out the exchange, refund the funds or refuse service where there are lawful grounds to do so.

8.2. When refunding funds suspended as part of an AML check, GetBit may withhold a fee of up to 5% of the transaction amount, but no more than 100 USDT.

8.3. For users acting in good faith whose funds have not been confirmed as linked to illegal activity, the refund is made without any additional fees other than the blockchain network fee.

8.4. If a decision to refund the funds is made after the AML/KYC check is completed, the refund is made within 10 (ten) business days of the date the check is completed. Actual refund times may depend on the specifics of the blockchain network used, technical limitations of the payment infrastructure or external circumstances beyond the Operator's control.

9. Restrictions on jurisdictions and sources of funds

To reduce AML/CFT risks, GetBit does not provide services to users who are located in, registered in or have a significant connection with jurisdictions classified as high-risk or unacceptable-risk under international and industry recommendations (including FATF, UN and EU sanctions lists and other sources of country risk assessment).

Users from the following states and territories are not served, and any funds received are to be returned to the sender unless there are legal restrictions:

United States;

Afghanistan;

Albania;

Angola;

Algeria;

Barbados;

Botswana;

Burma (Myanmar);

Burundi;

Cambodia;

Central African Republic;

Chad;

Congo;

Guinea (Conakry);

Côte d'Ivoire;

Cuba;

Democratic People's Republic of Korea (DPRK);

Egypt;

Equatorial Guinea;

Eritrea;

Ghana;

Guinea-Bissau;

Haiti;

Guyana;

Iran;

Iraq;

Lao People's Democratic Republic;

Lebanon;

Libya;

Mali;

Morocco;

Nepal;

Nicaragua;

North Macedonia;

Pakistan;

Qatar;

Saudi Arabia;

Somalia;

South Sudan;

Sudan;

Syria;

Tunisia;

Uganda;

Vanuatu;

Venezuela;

Yemen;

Zimbabwe;

Jamaica.

Restricted sources of funds:

WhiteBit;

HODLHODL;

Grinex;

GetBit may update the list of high-risk jurisdictions in line with changes to international sanctions regimes, FATF Recommendations and monitoring requirements without prior notice to users.

10. Data storage and interaction with authorities

10.1. Data obtained through AML procedures is processed and stored within a secure internal environment with restricted access.

10.2. GetBit provides information in response to official requests from competent authorities in the manner and to the extent provided for by applicable law.

11. Final provisions

11.1. GetBit may amend this Policy to keep it up to date and to comply with the requirements of monitoring services and the law.

11.2. The updated version of the Policy takes effect from the moment it is published on the GetBit website.

AML / KYC Policy