1. General Provisions

This AML/CFT Policy establishes the internal rules and procedures of RDF Exchange aimed at preventing money laundering, terrorist financing, and other unlawful activities. The Company operates in accordance with the current legislation of Ukraine, international FATF standards, and its internal security procedures.

The purpose of this Policy is to ensure transparency of financial operations, minimize risks associated with illicit financial activities, and safeguard both clients and the Company.

2. Principles of AML/CFT Compliance

RDF Exchange adheres to the following principles:

• Identification and verification of clients in cases required by law or internal company rules.
• Monitoring of transactions to detect suspicious activity and abnormal patterns.
• Recording and storing data in accordance with legal requirements.
• Refusal to execute a transaction if suspicious or illegal actions are identified.
• Cooperation with competent authorities in cases stipulated by law.

3. KYC: Customer Identification and Verification

RDF Exchange reserves the right to require clients to undergo the KYC (Know Your Customer) procedure, which may include:

• providing an identity document;
• identity verification via video, photo, or other available methods;
• confirmation of ownership of a cryptocurrency wallet;
• documents confirming the source of funds (bank statements, income information, documents proving lawful origin of assets).

Mandatory clause (as required by the client):

RDF Exchange reserves the right to request KYC verification and documents confirming the source of funds for both individual transactions and overall client activity if the operation does not pass internal security checks or if unusual activity is detected (e.g., transaction structuring, suspicious repeated transfers, alerts from the liquidity provider, etc.).

If the requested information is not provided, the Company reserves the right to refuse the transaction.

4. Transaction Monitoring

The Company continuously analyzes transactions to detect:

• atypical usage patterns of the service;
• signs of evading identification requirements;
• operations inconsistent with the client’s financial profile;
• transactions potentially linked to illegal activities.

If concerns arise, RDF Exchange may request additional information or conduct enhanced due diligence.

5. Right to Suspend or Withhold a Transaction

Mandatory clause (as required by the client):

RDF Exchange has the right to temporarily withhold, suspend, or delay a transaction (even if the initial AML risk assessment was within acceptable limits) if the internal security system or Company personnel determine that additional verification is necessary. This may include clarifying customer data, verifying the source of funds, or re-identifying the client.

The Company acts exclusively within the framework of Ukrainian law and applicable international AML/CFT standards.

6. Refusal to Provide Services

RDF Exchange may refuse to process a transaction in the following cases:

• inability to verify the client’s identity;
• the client’s refusal to provide documents or respond to requests for additional information;
• suspicion of illegal origin of funds;
• the request does not comply with legal requirements;
• the client’s activity may harm the Company or contradict Ukrainian law.

7. Data Retention

The Company retains all necessary transaction data, KYC documentation, internal verification records, and monitoring results for the period required under Ukrainian legislation.

8. Confidentiality and Data Protection

All collected information is used solely for AML/CFT compliance purposes. Client data is securely protected and not disclosed to third parties except as required by law.

9. Client Responsibility

The client confirms that they:

• provide accurate and up-to-date information;
• conduct transactions lawfully;
• do not use the service for illegal activities;
• agree that if false or misleading information is detected, the Company may suspend or cancel the transaction.

10. Amendments to the Policy

RDF Exchange reserves the right to amend this Policy in accordance with changes in legislation, regulatory requirements, or internal security procedures. The current version of the Policy is always available on the Company’s website.