AML Policy

1. General Provisions. AML and KYC Principles
Money laundering is a process by which funds or material assets obtained through illegal activities (terrorism, drug trafficking, illegal arms trade, corruption, human trafficking, and other crimes) are converted into legitimate financial resources in order to conceal their true origin.
AML (Anti-Money Laundering) — principles aimed at combating money laundering, terrorist financing, and the proliferation of weapons of mass destruction.
KYC (Know Your Customer / Know Your Client) — a principle governing the operations of financial institutions that requires them to verify the identity of their clients.
ProtonPlus adheres to strict standards in the prevention of money laundering and terrorist financing. We are committed to ensuring the transparency and security of all financial transactions conducted on our platform.

2. Collection and Storage of User Data
In accordance with AML/KYC principles, ProtonPlus collects and stores the following user data:

• email addresses
• IP addresses
• account numbers, electronic wallet addresses, cryptocurrency addresses, and other payment details
• all text data and images submitted by the client

By submitting an order, the User confirms that they:

• are prepared to undergo the identity verification procedure;
• undertake to provide all requested data and files;
• are prepared to patiently await the completion of the verification procedure without filing any claims against the Service.

3. AML and KYC Transaction Verification
ProtonPlus uses custodial services to receive user funds at deposit addresses. Risk assessment of incoming transactions is carried out:

• based on the exchange's proprietary verification algorithms;
• based on the results of transaction checks performed by the AML department of the custodial service.

An order is suspended upon detection of one or more of the following indicators:

• exceeding permissible risk thresholds;
• splitting of funds into multiple parts within a short period of time;
• presence within the transaction of funds that may pose a risk to the receiving party;
• other criteria forming part of the internal transaction analysis algorithm.

If analysis reveals a connection between the received funds and money laundering, criminal activity, or any other risk:

• Processing of the order is suspended.
• The user is requested, via the order's internal chat, to provide documents, photo/video materials, and explanations regarding the origin of funds.
• Upon successful verification and absence of money laundering indicators, funds are returned to the user at the agreed address, minus the transaction sending fee.
• Upon successful verification where a connection to money laundering is confirmed, funds are returned minus the transaction sending fee and a Service fee of 1% of the order amount (minimum 40 USD, maximum 100 USD).

The User agrees that suspended funds cannot be returned until the verification procedure is completed.

4. AML Analyzer Used
For automated risk assessment, ProtonPlus uses the certified AML analyzer AMLBot. The tool calculates a Risk Score for each incoming transaction based on transaction graph analysis and identifies connections to known illegal addresses, sanctioned entities, and high-risk services.

The Risk Score is calculated based on data from the following sources:

• AMLBot's proprietary address and cluster database;
• public sanctions lists (OFAC, EU, UN, etc.);
• data from law enforcement agencies and partner AML providers;
• internal algorithms of the ProtonPlus custodial service.

The final decision on a transaction is made taking into account the combined results of automated verification and manual AML analysis conducted by Service specialists.

5. AML/KYC Verification Stages and Timeframes
Stage 1. AML Transaction Check
Upon receipt of a deposit, two independent checks are performed:

• The custodial service performs an automated check at the moment funds are credited to the deposit address and calculates a Risk Score based on its own algorithms.
• The ProtonPlus exchange service performs a manual transaction check via AMLBot, verifying the origin of funds and the connection of addresses to illegal activity, sanctioned entities, and high-risk services.

If no violations are identified as a result of both checks, the transaction is processed in the normal course.

Stage 2. Order Suspension and User Notification
If permissible risk thresholds are exceeded — based on the results of the custodial service's automated check or ProtonPlus's manual check — the order is suspended. The user receives a notification in the order's internal chat requesting the necessary documents and explanations.

Stage 3. Submission of Documents by the User
The user provides the requested materials, including:

• a selfie with a government-issued identity document;
• documents confirming the origin of funds;
• screenshots, statements, and other information corroborating the details provided;
• additional materials as requested by the Service.

In the event of failure to provide documents, the Service reserves the right to refuse to execute the transaction.

Stage 4. Manual Verification and Decision-Making
AML specialists of the Service review the submitted materials and issue a decision to resume the transaction or to refuse it. Review timeframes:

• basic AML check — typically from 10 minutes to 24 hours;
• if a transaction is blocked by the exchange — up to 48 hours;
• in-depth check — in certain cases up to 14 business days from receipt of the complete documentation package.

Stage 5. Execution of Decision
Upon a positive decision, verification is deemed complete and the transaction is resumed, or funds are returned to the user in accordance with the Service's terms.
If verification has not been passed or the documentation package is incomplete, the transaction remains suspended until all required materials are received. ProtonPlus reserves the right to request additional information as necessary.
Funds in which a connection to unlawful activity has been identified are subject to freezing for the duration of the investigation.

6. Prohibited Platforms
The use of the following platforms for order payments is prohibited. Transactions involving these platforms are subject to blocking; to unblock funds, the user is required to undergo the verification procedure.

Sanctioned and blocked platforms:

• Garantex, Grinex, Hydra, Payeer, and other sanctioned platforms;
• any darknet marketplaces;
• platforms designed to enhance transaction anonymity (mixers): Trocador, AnonExch, and similar services.

Please note that some of the listed platforms may be assessed as low-risk by certain AML providers — nevertheless, ProtonPlus does not work with them and blocks related transactions.

7. Permissible Risk Category Thresholds
0% (fully prohibited categories):
Sanctions, Terrorism, Darknet Marketplace / Service, Ransomware / Malware, Mixing Service, Child Abuse, Stolen Funds / Stolen Coins / Stolen Credit Cards, Scam / Fraud / Phishing, Protocol Privacy, Drugs, Gambling, Ransom, Blackmail, Human Trafficking, Illegal Weapons, Fake Documents, Smuggling, Illegal Migration, Illegal Service, PEP, Corruption, DDOS Service, Enforcement Action, Personal Data (US / EU), High Risk / Sanction Country.

Up to 5% (high-risk categories):
ATM, Exchange | High Risk, Liquidity Pools, P2P Exchange | High Risk, Unnamed Service, Online Marketplace, Bridge, Precursors / China Precursors Manufacturing, Personal Data Other, Stolen Database, Laundering of Money, Illegal Financial Transactions, Paramilitary Organization, Cracked Software.

An additional key indicator is the splitting of available funds into parts for exchange via separate orders — such transactions may be deemed suspicious regardless of Risk Score values.

8. Monitoring and Cooperation with Authorities
ProtonPlus actively monitors all transactions for suspicious activity and works closely with custodial services responsible for the storage of user funds. Upon receipt of an official request from law enforcement authorities, ProtonPlus reserves the right to transmit all available information about a user:

• directly to law enforcement authorities;
• through the security department of the custodial service.

In accordance with international law, ProtonPlus is not obligated to notify a user that their activity has been deemed suspicious and reported to the relevant authorities.

9. Right to Refuse Transactions
ProtonPlus reserves the right to refuse to process any transaction if there are grounds to believe it is connected to money laundering or any other criminal activity.