Both international and local regulations and legislation require the LovanPay exchange service to implement effective internal procedures to prevent any illegal activity and take all necessary measures to do so.

The AML/KYC policy covers the following issues:

•   — Verification procedures;
•   — Transaction monitoring;
•   — Risk assessment;
•   — Address monitoring.

1. Verification procedures

1.1 Proof of identity

The verification procedure requires the User to provide the service administration with authentic documents (for example, an international passport, an account statement, a utility bill, etc.).

The service also reserves the right to additionally check certain Users who have aroused suspicion. The verification process includes the provision of documents confirming the User's identity.

1) To confirm the identity, the User must provide one of the following documents, as well as a selfie with this document:

— a civilian passport;
— international passport;
— ID card.

*You need to take a selfie holding in your hand one of the documents mentioned above, as well as an A4 sheet on which the information is written: the date of verification, the application number, the LovanPay website.

2) To verify the address, the User must provide one of the following documents:

— an extract from the bank, where the address of your actual residence is clearly visible; — the utility bill, where the address of your actual residence is clearly visible; — tax documents that clearly show the address of your actual residence; — a document confirming the address of your actual residence, issued by the local authorities, where the address of your actual residence is clearly visible.

(The date of receipt of the document is no more than 3 months)

1.2. Bank card verification

Users who want to make an exchange with a bank card must first verify it.

2. Risk assessment

Funds sent from Garantex, Rapira and Capitalist services can be permanently blocked by cryptocurrency exchanges and payment systems.

The service, in accordance with international requirements, verifies transactions for risk using AML services.

In this regard, the transaction/address may be rejected if the total risk exceeds 50%. Also, the Service may refuse to provide services to the User if the risk exceeds 0.5% in the following categories:

• • Illegal Service
• • Mixing Service
• • Fraudulent Exchange
• • Darknet Marketplace
• • Darknet Service
• • Ransom
• • Scam
• • Stolen Coins
• • Terrorism Financing
• • Sanctions
• • Illicit Actor/Organization
• • High-Risk Jurisdiction
• • Gambling
• • Fraud Shop
• • Enforcement action
• • Child Exploitation

If the transaction/address has high-risk tags, the User must pass a KYC check to verify their identity. After passing the KYC verification, the refund will be made minus the network commission. Funds are refunded to the client's address within 24 hours.

3. Conducting an exchange

The service warns users against attempts to use LovanPay for money laundering, terrorist financing, fraud of any kind, as well as from using the service to purchase prohibited goods and services.

To prevent illegal transactions, the Service sets certain requirements for all Applications created by the User:

3.1. The sender and recipient of the Request Payment must be the same person. Transfers in favor of third parties are strictly prohibited using the services of the Service.

3.2. The personal data entered by the User in the Application, as well as other data transmitted by the User to the Service, must be reliable and up-to-date.

3.3. If the administration of the Service has reasonable suspicions that the user is trying to use the services of the Service for money laundering or for the purpose of conducting any other illegal operations, the administration has the right:

— suspend the user's exchange operation; — request identification documents from the user; — request other information related to payments;

3.4. All information provided by the client may be transferred to the regulatory authorities in the following cases:

— at the request of law enforcement agencies; — by decision of the courts of different instances; — at the request of Payment system administrations. The Service reserves the right to:

• 1) require the User to provide additional information revealing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
• 2) block the account and any operations related to the User, transfer to the financial activity control and/or law enforcement authorities at the place of registration of the Service and, if necessary, at the Client's registration address all information and documents available on the incident;
• 3) require the User to provide identification documents, video verification, registration address, and ability to pay;
• 4) to refund digital assets only to the banking details from which the transfer was made, after a full check by the Service's security service, if it was possible to verify the legal origin of the Client's funds.;
• 5) to refuse the User to withdraw funds to the account of third parties without explaining the reasons;
• 6) freeze User funds until the incident is fully investigated;
• 7) monitor the entire transaction chain in order to identify suspicious transactions;
• 8) to refuse to provide the service to the User if the Service has reasonable suspicions about the legality of the origin of digital assets or in the case when it is impossible to track the entire chain of movement of assets from the moment of their appearance and keep funds in special accounts of the Service.