AML/CTF Policy

The administration of DualCoin (dualcoin.io) recognizes the risks associated with the use of digital assets for the purposes of money laundering and terrorist financing. For this reason, the service implements a set of measures aimed at preventing and mitigating risks related to Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF).

In its operations, DualCoin follows the international standards and recommendations of the Financial Action Task Force (FATF), the provisions of the Sixth Anti-Money Laundering Directive (6AMLD), as well as other applicable international regulations and industry best practices within the digital asset sector.

The purpose of this policy is to minimize the risk of the DualCoin service being used for illegal activities and to ensure the safety and integrity of both users and partners.

SERVICE AUTHORITIES AND RIGHTS

In order to implement this policy, the DualCoin service reserves the right to apply the following monitoring and control measures.

Appointment of a Responsible Officer

The service appoints a designated compliance officer — MLRO (Money Laundering Reporting Officer) — responsible for overseeing compliance with this AML policy. The MLRO conducts transaction analysis, evaluates potentially suspicious activities, and communicates with relevant regulatory authorities when necessary.

Transaction Monitoring

All transactions processed through the service are subject to automated and/or manual monitoring procedures. If suspicious activity is detected, the service reserves the right to initiate an additional compliance review.

Where indications of unlawful activity are identified, the service may report relevant information to competent authorities through the designated responsible officer.

Request for Additional Information

As part of compliance procedures, the service may request additional information or documentation from the user, including identity verification data and proof of the origin of funds.

Such requests may be initiated either as part of the service's internal compliance procedures or upon request from regulatory authorities, cryptocurrency exchanges, liquidity providers, payment processors, or other authorized entities.

Suspension of Operations

DualCoin reserves the right to temporarily suspend a transaction, restrict access to a user's account, or terminate service provision if there are reasonable grounds to believe that a transaction may be associated with illegal activities.

TRANSACTION RISK ASSESSMENT AND AML CHECKS

This policy defines the risk assessment criteria applied to transactions conducted through the DualCoin service.

In order to mitigate AML risks, the service does not accept funds originating from sources associated with sanctioned entities, prohibited platforms, darknet marketplaces, fraudulent schemes, or other high-risk categories.

All incoming transactions are analyzed using specialized blockchain analytics and AML screening tools. If the AML analysis indicates an elevated risk level, the transaction may be suspended pending further compliance review.

Factors that may indicate elevated risk include, but are not limited to:

• a Risk Score exceeding 70%
• the presence of High Risk labels, including categories such as Dark Market, Sanctions, Fraud, Illegal Services, or similar indicators
• suspicious or anomalous transaction behavior patterns

If such risk indicators are identified, the service reserves the right to suspend the transaction until the investigation is completed and the necessary clarifications are obtained.

It should be noted that the list of risk indicators described above is not exhaustive. The responsible compliance officer may make additional determinations based on transaction analysis and other relevant circumstances.

IDENTIFICATION PROCEDURES (KYC / SOF)

As part of investigations related to suspicious transactions, DualCoin may initiate user identification procedures including KYC (Know Your Customer) and SoF (Source of Funds) verification.

Within these procedures, the user may be required to provide the following information or documentation:

• a valid government-issued identity document
• a selfie or video verification with the identity document
• proof of residential address
• information regarding the origin of the funds used in the transaction
• additional supporting materials or explanations related to the transaction activity