KYC/AML Policy

1.1. Compliance with international and national KYC and AML requirements.

1.2. Prevention of the use of Stormpay.online for money laundering, terrorist financing, and other criminal activities.

1.3. Implementation of customer identification and verification procedures.

1.4. Training employees on KYC/AML rules and procedures.

2.1. **KYC** — customer identification and verification procedures.

2.2. **AML** — measures to prevent and detect money laundering and terrorist financing.

2.3. **Dark Market** — an online platform specializing in the sale of illegal goods or services.

2.4. **Sanctions** — restrictions imposed by international organizations or states on countries, companies, or individuals.

2.5. **Stolen Coins** — cryptocurrency obtained through theft or fraud and subject to sanctions or investigation.

2.6. **Scam** — fraudulent schemes, including fake ICOs, "pyramids," and other forms of deception.

2.7. **High-risk transaction** — a transaction with increased risk, including suspicious behavior patterns, large amounts, and transactions with jurisdictions with low financial transparency.

3.1. The client undertakes to undergo the verification procedure at the request of the service. Stormpay.online has the right to request additional documents.

3.2. Verification includes, but is not limited to:

• Passport (main page or front side)
• Passport (second page or back side)
• Document confirming the address of residence

4.1. Stormpay.online applies mechanisms to detect transactions related to money laundering or terrorist financing.

4.2. For these purposes, the service uses specialized solutions (e.g., **AMLBot** and other international analysis systems).

4.3. All client operations are subject to monitoring to detect suspicious or anomalous activities.

In case of increased AML risk or detection of high-risk funds (Dark Market, Sanctions, Stolen Coins, Scam, etc.), Stormpay.online may:

• Suspend the operation for up to 14 days or hold funds until the check is completed.
• Request photos/videos of the client with an identity document.
• Request screenshots or videos from the client's personal crypto wallet.
• Return digital assets only to the details from which the transfer was made, or to new ones — after a full check.
• Request other documents and materials.
• Refuse to withdraw funds to third-party details without explanation.
• Refund funds within 14 calendar days after the decision. Refund is possible only after completion of the check and confirmation of details. The refund fee is deducted from the client's funds. If the client does not provide data within 3 months, the funds are not returned.
• All communication is carried out exclusively by email specified in the application.
• At the request of law enforcement agencies, Stormpay.online may hold funds until the final decision of the competent authorities.
• If the check reveals that funds are blocked due to sanctions restrictions, they may remain frozen until the sanctions are lifted.

6.1. Employees are required to immediately inform management upon detection of suspicious activities.

6.2. Reports of suspicious activity are sent to the relevant authorities within the time limits established by law.

7.1. All client documents and data are stored for at least 5 years after the end of the relationship.

7.2. Client personal data is protected and processed in accordance with the current privacy rules (see **Privacy Policy**).

8.1. The policy is reviewed at least once a year or when legislation changes.

8.2. Responsibility for updating lies with the Compliance department of Stormpay.online.

8.3. AML rules may be changed by the service management unilaterally.