AML Policy

AML/CTF and KYC Policy

Anti-Money Laundering Policy (AML policy)

Effective date: 01.11.2021. Updated on 27.05.2022. This AML Policy (hereinafter referred to as the Policy) governs the activities of Xstable.pro in relation to combating money laundering and its involvement in combating money laundering and terrorist financing.

1. Terms and Definitions

Xstable.pro – is the trademark of the system that provides Users with the possibility to exchange digital and electronic currency.
Service – a system for providing Internet services for the exchange, sale and purchase of digital and/or electronic currencies.
User – any individual using the services of Xstable.pro.
Digital Currency – Bitcoin, Litecoin, Ethereum and any other blockchain-based currencies.
Electronic Currency – funds held in user accounts of electronic payment systems.
Service Services – assistance in carrying out P2P transactions between individuals for the purchase, sale and exchange of digital currencies, as well as other services, information about which is posted on the Service showcase.
Card Verification – verification that a card (or account) belongs to its owner. The conditions for verifying ownership are established by the Service and are performed once for each new account (card) of the User.
Money Laundering – giving a lawful appearance to the ownership, use or disposal of funds or other property obtained as a result of committing a crime. Xstable.pro strictly follows the laws prohibiting us or any of our employees from knowingly engaging or attempting to engage in any activities in any way related to money laundering. Our anti-money laundering policy is aimed at improving the safety of Clients and the services provided by the Service.
Terrorist Financing – the intentional provision or collection, by any means, directly or indirectly, of funds with the intention that such funds be used, or with the knowledge that they will be used, to commit terrorist acts.

2. Measures Taken within the Framework of AML Policy Compliance

The administration of the Xstable.pro service, understanding the public danger of crimes related to money laundering and terrorist financing, has developed a set of organizational and legal measures aimed at complying with national legislation, as well as the requirements of the intergovernmental organization FATF.
European AML regulation is based on a number of legislative directives. Namely, the EU issued the Sixth Anti-Money Laundering Directive (6AMLD), which entered into force on 02 December 2018.
Other legislative acts aimed at combating the legalization of proceeds of crime and the financing of terrorism include the following acts:
• 5th Anti-Money Laundering Directive ((EU) 2018/843);
• Proceeds of Crime Act 2002;
• Terrorism Acts 2000 and 2001;
• Counter-Terrorism Act 2008;
• Treasury Sanctions Notices;

3. Application of the KYC Policy (know your customer).

3.1. Mandatory identification of Users who are allowed to conduct transactions on our Service. To verify a User, the Administration has the right to require the following data:
• take a photograph (“selfie”) with a document certifying the citizen’s identity: a scanned copy of the front and back sides of an official photo identity document, i.e. a valid passport, driver’s license or other national identity document;
• confirm place of residence: an official document issued within the last 3 months clearly indicating the Client’s name and address specified when registering on the Xstable.pro website. This may be a utility bill (water, electricity or landline telephone) or a bank statement. The copy must include: full name, full residential address, date of issue (within the last 3 months), name of the authority that issued the document, with an official logo or seal;
• provide a copy of the front and back sides of the bank card and/or a photograph of your bank card taken against the background of the main page of the Service (service showcase). To ensure confidentiality and security, only the last 4 digits of your credit card must be visible. It is allowed to hide the 3 digits on the back of the card (CVV code).
3.2. The administration of the Xstable.pro service will take steps to confirm the authenticity of the documents and information provided by Users. Identification information will also be verified using secondary sources, and the administration of the service reserves the right to continue investigating cases in order to obtain complete confidence in the authenticity of the provided documentation.
3.3. The administration of the Xstable.pro service reserves the right to monitor User data on an ongoing basis, especially in cases where the User’s identification information has been changed or the User’s activity appears suspicious (unusual for a specific User). In addition, the Administration reserves the right to request up-to-date documents from Users even if they have passed authenticity verification in the past.

4. Ongoing Monitoring of Operations Passing through the Service.

4.1. We exercise ongoing control over all Exchange Requests created on the Xstable.pro website. The administration of the service notifies Users of the prohibition on carrying out exchange operations from third parties using their account.
4.2. Appointment of a responsible person (MLRO — Money Laundering Reporting Officer) exercising control and supervisory powers over the implementation of the provisions of this Policy.
4.3. Application of a risk-based approach (RBA — Risk-Based Approach). We implement different verification levels depending on the volume and number of operations performed by the User.
4.4. Improving the professional skills and knowledge of the Xstable.pro team employees regarding compliance with the Policy requirements.
4.5. Cooperation with government authorities in cases established by law. In the event of an official request from law enforcement or judicial authorities, we will be obliged to provide them with the requested information. The service administration also has the right to provide data requested by official representatives of payment systems.
4.6. Improving the security of the Xstable.pro service software. We care about the reliability and security of your transactions. In this regard, we continuously improve our IT department, whose main task is to protect the website from unauthorized access by malicious actors.
4.7. In cases prescribed by law, the administration of the Xstable.pro service may require a regulatory requirement to verify the source of fiat money and/or cryptocurrency in order to ensure that the sources of Funds used by the Client for exchange are lawful. A document confirming the source of origin of Funds may be a bank statement for fiat money or a video demonstrating the details of a wallet transaction for cryptocurrency.
4.8. In accordance with this Policy, the Service administration will:
4.8.1. monitor all transactions. The Administration reserves the right to ensure that reports on the suspicious nature of transactions are submitted to the appropriate law enforcement authorities through the Responsible Officer;
4.8.2. request any additional information and documents from the User if the User carries out suspicious transactions, as well as at the request of a regulator (the role of the regulator may be performed by an exchange, a government institution or another organization having the appropriate legal grounds);
4.8.3. suspend or terminate the User’s account if there is a reasonable suspicion that such User is involved in illegal activity.
At the same time, the above list is not exhaustive, and the Responsible Officer will monitor Users’ transactions daily to determine whether such transactions should be reported and treated as suspicious, or whether they should be treated as bona fide.

5. Country of Residence.

This Policy defines our AML/CTF risk criteria. To reduce this risk, the administration of the Xstable.pro service does not accept Clients who reside in the following countries with an increased risk criterion.
Sources used for categorization:
• Transparency International;
• Know Your Country;
• FATF list of high-risk jurisdictions;
• EU list of high-risk jurisdictions;
• Countries where digital assets are prohibited or where trading restrictions exist;
• Countries where digital assets are not prohibited;
• Countries subject to the UN Security Council sanctions regime.
All Clients residing in the countries listed below are prohibited from being served by the Xstable.pro service and cannot be accepted as Users. Any Clients from these countries will be refused service, and any funds will be returned to the source.
Full list of prohibited jurisdictions:
United States
Afghanistan
Albania
Angola
Algeria
Bangladesh
Barbados
Bolivia
Botswana
Burma (Myanmar)
Burundi
Cambodia
Central African Republic
Chad
Congo
Conakry
Ivory Coast
Cuba
Democratic People’s Republic of Korea (DPRK)
Ecuador
Egypt
Equatorial Guinea
Eritrea
Ghana
Guinea-Bissau
Haiti
Guyana
Iran
Iraq
Lao People’s Democratic Republic
Lebanon
Libya
Mali
Morocco
Myanmar
Nepal
Nicaragua
North Macedonia
Pakistan
Panama
Qatar
Saudi Arabia
Somalia
South Sudan
Sudan
Syria
Tunisia
Uganda
Vanuatu
Venezuela
Yemen
Zimbabwe
Jamaica
The administration of the Xstable.pro service also does not accept Clients from disputed territories, as they do not provide generally recognized official documents, including:
Pridnestrovian Moldavian Republic
Nagorno-Karabakh Republic
Republic of Abkhazia
Republic of Somaliland
Republic of South Ossetia
Turkish Republic of Northern Cyprus
Republic of China (Taiwan)
Republic of Kosovo
Sahrawi Arab Democratic Republic
Republic of Artsakh

6. KYT Policy (Know Your Transaction)

Effective date: 01.11.2021. Updated on 27.05.2022. The KYT Policy (Know Your Transaction) is aimed at identifying the Client of a transaction in the event of a precedent where the Service has reasonable suspicions that the Client is using Xstable.pro for an improper purpose.
Such a precedent may arise if the Service suspects the Client of illegal actions that may be qualified as laundering or attempted laundering of digital assets obtained unlawfully, or if the funds are of clearly criminal origin. For these purposes, the Service has the right to use any lawful information, third-party tools for analyzing the origin of digital assets, as well as its own screening system developments.
In such case, the Xstable.pro Service reserves the full right to:
• Require the Client to provide additional information disclosing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
• Block the account and any operations related to the Client, transfer all information and documents available regarding the incident to financial supervisory and/or law enforcement authorities at the place of registration of the Service and, if necessary, at the address of the Client’s registration;
• Require from the Client documents confirming identity, physical existence, registration address and solvency;
• Return digital assets only to the details from which the transfer was made, or switch to other details after a full check by the Service security department, if it was possible to verify the lawful origin of the Client’s funds;
• Refuse the Client withdrawal of funds to the account of third parties without giving reasons;
• Hold the Client’s funds until the incident has been fully investigated;
• The Service reserves the right to control the entire transaction chain in order to identify suspicious transactions;
• The Service reserves the right to refuse to provide the Client with the service if the Service has reasonable suspicions regarding the legality of the origin of digital assets and to hold funds in special accounts of the Service;
• The Service reserves the right to refuse to provide the Client with the service if the Service has reasonable suspicions regarding the legality of the origin of digital assets and to hold funds in special accounts of the Service, in the event that it is impossible to trace the entire chain of movement of digital assets from the moment of their appearance.

7. Conditions for Refunding Funds Stopped for Verification Based on the Results of AML Transaction Analysis

Refund of funds is carried out after a full check by the Service security department, which may include detailed verification of the sender. Refund of funds is carried out minus a fee of up to 5% of the transaction amount to cover labor costs for processing the request and organizing the refund.
A Refund, subject to approval by the Service, will be processed by the Service within 7 (seven) calendar days starting from the date on which the User was notified of the Service’s decision regarding the User’s refund request.
When processing a refund, after passing the check (verification), the User is obliged to confirm the details for receiving the refund.