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AML & KYC Policy

How ReChange prevents money laundering, terrorist financing and sanctions evasion.

Version 1.0 Effective 31 August 2026

ReChange is a custodial crypto exchange: funds pass through addresses we control before reaching merchants. This policy applies to every merchant account, every Invoice, and all ReChange staff.

It sits alongside the Terms of Service and the Privacy Policy, and takes precedence on compliance matters.

Our programme is built to the FATF Recommendations, in particular Recommendation 15 on virtual assets and Recommendation 16 (Travel Rule), together with applicable local AML/CTF legislation and sanctions regimes.

Board Approves this policy, owns the risk appetite, receives compliance reporting quarterly
MLRO Named, sufficiently senior, independent. Owns day-to-day compliance and has authority to freeze funds
Compliance team Runs verification, screening, alert review and escalation
All staff Must escalate suspicion to the MLRO immediately

We score every merchant at onboarding and re-score on trigger events. Controls scale with the score.

Sector Software/SaaS = lower risk. Gambling, adult, precious metals = higher risk
Geography Effective AML supervision = lower. FATF grey/black list = higher
Ownership Transparent = lower. Nominees, opaque structures, PEP involvement = higher
Volume pattern Stable = lower. Sudden spikes, round-number flows = higher

An account can be created before verification, but processing limits apply until it is complete.

Tier 0 — Registered Verified email only. Sandbox, no live processing
Tier 1 — Basic Full name, DOB, address, government photo ID, liveness check. Up to EUR 15,000 per 30 days
Tier 2 — Business Tier 1 for each director and beneficial owner (25%+), plus incorporation docs, ownership structure, business model
Tier 3 — Enhanced Tier 2 plus source of funds/wealth evidence, financial statements, MLRO sign-off
We verify merchants, not their customers. If your regulatory position requires you to know your customers, that obligation remains yours.

We escalate to Tier 3 whenever:

  • A beneficial owner or director is a politically exposed person
  • The merchant touches a high-risk third country
  • The ownership structure is opaque or uses nominees
  • Volumes or counterparties diverge from what was declared
  • Screening produces a sanctions or adverse-media hit
  • Blockchain analytics attributes meaningful illicit exposure
  • We screen every applicant against UN, EU, OFAC, UK OFSI and local lists before activation
  • We re-screen the entire customer base when any list is updated
  • We screen blockchain addresses against sanctioned-address designations
  • We apply the 50% ownership-and-control rule
A confirmed sanctions match is not negotiable. We freeze immediately, refuse the transaction, and report to the competent authority.
Comprehensively sanctioned Prohibited. No onboarding, no processing
FATF black list Prohibited absent explicit legal carve-out and board approval
FATF grey list Permitted with mandatory enhanced due diligence

Using a VPN, proxy or nominee to get around a restriction is a material breach of the Terms.

We will not knowingly process value connected to:

  • Proceeds of any crime, fraud, tax evasion, corruption
  • Terrorist or proliferation financing
  • Ransomware, darknet markets, controlled substances
  • Child sexual abuse material — reported immediately
  • Human trafficking, forced labour, organ trade
  • Funds routed through mixers, tumblers or chain-hopping
  • Stolen assets, Ponzi schemes, unlicensed gambling

Monitoring is automated, with human review of every alert. Signals include:

Structuring Payments just under a reporting threshold, repeatedly
Layering Rapid in-and-out with no commercial purpose
Illicit provenance Deposits traced to mixers, darknet clusters or sanctioned addresses
Account takeover Sudden dormancy followed by a large flow

Where FATF Recommendation 16 applies, transfers above EUR 1,000 between regulated VASPs must carry originator and beneficiary information.

We may hold a payment, freeze a balance, or refuse a payout where screening produces a sanctions match, a monitoring alert is open, verification is incomplete, or the law requires it.

Rejected incoming payments are not automatically returned. Returning funds can itself be an offence if it puts criminal proceeds back into circulation.

Any staff member who forms a suspicion must escalate to the MLRO immediately. The MLRO files a suspicious activity report where the test is met.

Tipping off is a criminal offence. We will not tell you that a report has been filed.

Identification and verification data 5 years after the relationship ends
Transaction records 5 years from the transaction
Screening results 5 years
Suspicious activity reports 5 years, or longer if directed
  • Describe your business model accurately
  • Complete verification and keep documents current
  • Answer information requests within 10 business days
  • Process only your own receivables — no third-party funds
  • Hold whatever licences your activity requires
  • Apply your own AML obligations to your customers
  • Do not evade limits, thresholds or controls
  • Tell us promptly if funds you received are tainted
  • All staff complete AML training at induction and annually
  • Monitoring rules are tested against known-bad cases
  • An independent audit is carried out at least every two years
Compliance enquiries [compliance@rechange.pro]
Reporting misuse [mlro@rechange.pro]
Law enforcement requests [legal@rechange.pro]

Reports may be made anonymously. We do not retaliate against anyone who raises a concern in good faith.

Related: Terms of Service · Privacy Policy