AML / KYC Policy — Garantex.app

Last updated: September 29, 2026

Garantex.app is committed to preventing its Service from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud or any other financial crime. This AML/KYC Policy explains how we assess risk, when we ask for verification, what we ask for, and what happens to exchanges that cannot be cleared. It applies to every exchange and card purchase, in Standard mode and Anonymous mode alike, and forms part of our Terms of Service.

1. Our approach

We follow a risk-based approach. Most exchanges are completed without any identity check. Instead of asking every customer for documents, we monitor transactions and focus our checks on activity that shows higher risk. The level of scrutiny is proportionate to the risk: the more unusual or higher-risk an exchange is, the more information we may request.

2. Governance

Our compliance function is responsible for this policy, the screening rules, the review of flagged exchanges and cooperation with authorities. Staff involved in processing exchanges are trained to recognise suspicious activity. This policy and our risk assessment are reviewed regularly and whenever laws, typologies or our Service change.

3. Transaction monitoring and blockchain screening

Every exchange is screened automatically, and flagged exchanges are reviewed manually. Screening covers, among other things:

the deposit source and payout destination addresses, checked against blockchain analytics and known illicit or sanctioned addresses;
exposure of the funds, directly or through intermediaries, to darknet markets, mixers, scams, ransomware, hacks, stolen funds or sanctioned entities;
the amount and value of the exchange, the combined value of related exchanges and the speed with which they follow each other;
payment signals from our card payment partner, such as fraud and chargeback risk;
information from authorities, partners and other reliable sources.

4. Examples of risk indicators

funds that originate from or are sent to addresses linked to illicit activity or sanctioned persons;
splitting a large amount into several smaller exchanges (“structuring”), or repeated exchanges just below limits;
rapid movement of funds through multiple assets or networks with no clear purpose;
deposits from privacy-enhancing services or recently stolen funds;
use of the Service on behalf of third parties, or signs that the customer is being instructed or coerced by someone else;
inconsistent, false or altered documents or information;
card payments with signs of fraud, such as a cardholder name that does not match, or multiple cards used in a short time;
access from sanctioned jurisdictions.

A risk indicator is not an accusation. It only means that we need more information before we can continue.

5. When we ask for verification

We may put an exchange on hold and request verification when:

screening shows a risk indicator;
the value of an exchange, or of related exchanges, reaches thresholds set in our risk assessment;
our payment or liquidity partner requests it;
we are required to do so by law or by an authority;
we have doubts about information previously provided.

An exchange on hold shows the status “On hold – verification required”. To continue, open a support ticket with your Exchange ID and PIN; we will tell you exactly what is needed.

6. What we may ask for

6.1 Standard verification

a valid government-issued photo ID (passport, national ID card or driving licence) showing your full name, date of birth, photo and expiry date;
a selfie or short liveness check to confirm that you are the person on the document;
proof of address issued within the last three months (for example a utility bill or bank statement);
proof that you control the sending wallet (for example a signed message or a small test transaction).

6.2 Enhanced due diligence

For higher-risk cases we may also ask for:

source of funds – how you obtained the specific assets you are exchanging (for example exchange account statements, withdrawal records, payslips, sale agreements);
source of wealth – how your overall wealth was generated;
the purpose of the exchange and the relationship with the recipient;
information on whether you are a politically exposed person (PEP) or a family member or close associate of one.

6.3 Document requirements

Documents must be valid, complete, readable, unedited and in colour. Photos of screens and cropped documents are not accepted. Documents not in English or one of the site's languages may need a translation. We contact you about verification only through our support ticket system, where we explain how to submit documents securely. We will never ask for your PIN, private keys or seed phrase.

7. Review and outcomes

We aim to review submitted documents within one to three business days; complex cases can take longer. The possible outcomes are:

Cleared – the exchange continues. Because the rate is not guaranteed while on hold, it may be recalculated at the current rate, and you can choose a refund instead.
Refunded – if verification is not completed within a reasonable time (normally 30 days) or the risk cannot be resolved, the deposit may be returned to its source or a confirmed refund address, minus network fees, where the law permits.
Retained and reported – where the law requires it, funds may be frozen, retained or handed over to the competent authorities, and the matter reported. In such cases we may be legally prohibited from informing you.

8. Sanctions

We do not provide the Service to persons or entities designated on applicable sanctions lists, including those of the United Nations, the European Union, the United Kingdom and the United States (OFAC), to anyone owned or controlled by them, or to anyone located in, or ordinarily resident in, a comprehensively sanctioned country or region. We may block access from such jurisdictions and we screen addresses against sanctions data. Attempts to circumvent these measures, for example by using a VPN, are a breach of our Terms.

9. Prohibited activities

The Service must not be used in connection with money laundering, terrorist or proliferation financing, fraud, scams, ransomware, hacking, theft, extortion, darknet markets, illegal gambling, illegal goods or services, or the proceeds of any crime. Exchanges linked to such activity are refused and may be reported.

10. Anonymous mode

Anonymous mode means that we do not store your IP address, browser details or e-mail address with the exchange. It does not exempt an exchange from screening or verification. Anonymous exchanges are screened in exactly the same way, and a flagged anonymous exchange requires the same verification as any other. Documents submitted during verification are stored under this policy even if the exchange was placed in Anonymous mode.

11. Card purchases

Card payments are subject to additional checks by our payment partner, which may require identity verification, 3-D Secure authentication or other information before accepting the payment. The cardholder must be the person making the purchase. Payments with cards belonging to someone else are refused.

12. Record keeping

We keep exchange records, screening results, verification documents and related correspondence for as long as anti-money-laundering law requires – typically five years after the exchange or the end of the relationship – in a secure environment with restricted access. See our Privacy Policy for details.

13. Reporting and cooperation with authorities

We report suspicious activity to the competent financial intelligence unit and respond to lawful requests from law enforcement, courts and regulators. We may freeze funds where legally required. We will not disclose that a report has been made where the law prohibits it.

14. Your cooperation

By using the Service you agree to provide accurate information and documents promptly when requested. Providing false or altered information is a serious breach of our Terms and may be reported.

15. Contact

Questions about this policy or a held exchange: open a support ticket with your Exchange ID and PIN, or write to [email protected].