AML & Acceptable Use Statement
You do not upload identity documents to place a standard order here. No account, no passport scan, no selfie. That is the normal path and it is how the overwhelming majority of orders complete.
We are not going to tell you it is unconditional, because no honest exchange can. We screen addresses against sanctions and stolen-funds data, and in the specific circumstances listed in section 3 we may ask you a question before completing an order. Those circumstances are published below rather than left vague, so you know where the line is before you deposit rather than after.
1. Our position on identity verification
Most people who use a no-account exchange are not criminals. They are people who object, reasonably, to handing a passport scan and a selfie to every website that touches their own money, particularly after the succession of exchange and broker data breaches that leaked exactly those documents.
We agree with that objection, and we have built the service so that a standard order requires none of it. We collect what the transaction itself requires: the addresses, the assets, the amounts, and the times. Nothing about who you are. What we hold is set out in full in our Privacy Policy.
We also will not pretend to be outside the reach of financial-crime law, because that claim is what precedes an exchange being seized and its customers' funds with it. We screen, we keep records, and we cooperate with lawful orders. Those three facts and a no-documents standard path are compatible, and this page explains exactly how.
2. What we screen, on every order
Automatically, on every order, before payout:
- Sanctions screening of the deposit and destination addresses against lists maintained by the United Nations, the European Union, the United Kingdom (OFSI) and the United States (OFAC).
- Blockchain analytics on both addresses, using a commercial blockchain-analytics provider, to identify a direct or close association with sanctioned entities, known thefts and protocol exploits, ransomware collection addresses, darknet markets, or fraud campaigns.
- Geographic checks based on the country derived from your IP address, against our Restricted Jurisdictions list.
- Amount and pattern checks against the thresholds in section 3.
This is address screening, not identity screening. It runs against public blockchain data and published sanctions lists. It does not require anything from you, and in the ordinary case you will never know it happened.
3. When we may ask you for more
We may pause an order and ask you a question in these circumstances, and as a matter of policy we do not do so arbitrarily:
| Trigger | Threshold or condition | What we typically ask |
|---|---|---|
| Order value | A single order above the equivalent of EUR 1,000 | Source of funds; purpose of the transaction |
| Aggregate value | More than the equivalent of EUR 3,000 across linked orders within 30 days | Source of funds |
| Sanctions match | Any positive or near match on either address | Nothing. We cannot complete the order, and will act as the law requires |
| Tainted-funds indicator | Direct or one-hop exposure to a theft, exploit, ransomware address, or darknet market | How you acquired the funds; supporting evidence |
| Restricted location | Access from a jurisdiction on our restricted list | Nothing. The order is declined and refunded |
| Structuring pattern | See section 6 | Explanation of the pattern |
| Legal compulsion | A binding order from a court or competent authority | Whatever that order lawfully requires |
| Third-party deposit | Deposit funded by someone other than you | The relationship, and their details where required |
Absent one of these, we do not ask for identity documents.
4. What happens if we ask
- We tell you. You get a message stating that the order is held, which trigger applies, and what we need. We do not leave orders silently pending.
- You decide. You can provide what we asked for, or you can decline.
- If you provide it, we review within one business day and either complete the order or refund it. Anything you send us is held under the retention rule in our Privacy Policy and is not used for marketing, profiling, or any other purpose.
- If you decline, we refund the deposit to your refund address under section 9 of the Terms, less network costs. Declining is not treated as an admission of anything.
- The exception. Where a sanctions match or a binding legal order applies, we may be legally prohibited from refunding, from telling you why, or both. In that case we will tell you as much as the law permits. This is the one situation in which we cannot promise your funds back, and we would rather you knew that before depositing than after.
5. Prohibited use
You must not use this service in connection with:
- money laundering or terrorist financing;
- sanctions evasion, or transactions for a sanctioned person, entity, vessel, or jurisdiction;
- funds obtained through fraud, theft, extortion, ransomware, business email compromise, or the compromise of any account, wallet, exchange, bridge, or protocol;
- trafficking in people, weapons, or controlled substances;
- child sexual abuse material, in any form;
- ransomware payment collection;
- market manipulation, insider dealing, or any securities offence;
- Ponzi, pyramid, or other investment-fraud schemes;
- concealing assets from a court, a trustee in bankruptcy, an insolvency practitioner, or a tax authority;
- gambling operations where that is unlawful in the relevant jurisdiction;
- any other activity unlawful where you or we are located.
We decline these orders. We are not neutral about them, and we will not process one because it is profitable.
6. Structuring
Splitting a transaction into several smaller ones to stay below a threshold on this page is itself a red flag and, in many jurisdictions, an offence in its own right. Indicators we act on include a series of orders just below a threshold, several orders in quick succession from related addresses, and the same destination address receiving repeated payouts from separately created orders.
If you genuinely need to move an amount above our thresholds, contact support@buysellcrypto.exchange and ask. A direct request is straightforward to handle. A structured series is not, and it will attract exactly the attention you were trying to avoid.
7. Working with authorities
We respond to valid, lawful requests from competent authorities in the jurisdictions that apply to us. We disclose what a valid request lawfully requires, and no more. Where we are permitted to notify you of a request, we will; where a law or order prohibits notification, we cannot.
We do not volunteer customer records absent a legal obligation, and we do not sell or share them with commercial third parties. See our Privacy Policy for the complete list of who receives data and why.
8. Governance and record-keeping
- This policy is owned by our compliance function, reachable at compliance@buysellcrypto.exchange.
- Screening follows the FATF standards for virtual-asset transfers, including sanctions screening of both sides of every transfer.
- Order and screening records are retained for 5 years.
- Staff with access to order data receive financial-crime training at least once a year.
- This policy is reviewed at least once a year and after any material regulatory change.
9. Contact
Compliance and AML: compliance@buysellcrypto.exchange
General support: support@buysellcrypto.exchange
Law-enforcement requests: legal@buysellcrypto.exchange