AML / KYC POLICY
Last updated: 16 July 2025
1. General Provisions.
1.1. Bull Up Exchange (hereinafter — the Service) complies with the laws of Ukraine, EU AMLD6 and the FATF Recommendations on Anti‑Money Laundering, Counter‑Terrorist Financing (AML/CTF) and Know‑Your‑Customer (KYC) procedures.
1.2. This Policy aims to prevent the Service from being used to launder proceeds of crime, finance terrorism, commit fraud or engage in any other illegal activities.
2. Risk Criteria and Transaction Blocking.
2.1. All crypto transactions are screened via blockchain analytics (Chainalysis / Crystal / TRM or equivalent) and assigned a Risk Score from 0 to 100.
2.2. Transactions with a Risk Score > 70 are blocked automatically and set to “Pending AML”.
2.3. The Service reserves the right to block a transaction with a Risk Score of 50 – 69 if additional analysis indicates elevated risk.
2.4. Key High‑Risk Entities:
• Sanctions (OFAC / EU / NBU, etc.);
• Terrorist Financing;
• Darknet marketplace / illegal service;
• Ransomware / Stolen coins;
• Scam / Fraud.
2.5. If these entities account for more than 5 out of 100 points in the risk profile, the Service may withhold the deposit.
3. Prohibited Sources.
3.1. Deposits linked to the following services are not accepted:
OMG!OMG!, MEGA DARKNET MARKET, 1xBit, Black Sprut, FreeBitcoin, Primedice, Stake, Hydra, Wasabi, DuelBits, WEX Exchange, Garantex, NVSPC, Tornado, Gandhiji.io, DuckDice, Roobet, Bitzlato, Yolo Group, any crypto mixers and other resources subject to international sanctions.
4. Order Requirements.
4.1. The sender and recipient of a payment must be the same person. Third‑party transfers via the Service are prohibited.
4.2. All contact and personal data provided by the Customer must be accurate and up to date.
4.3. Creating orders through anonymous proxy servers, unknown VPNs or the Tor network is forbidden.
5. Enhanced Due Diligence.
5.1. If a deposit is marked “High Risk” under Section 2, the Service may:
• suspend the transaction;
• request identity documents (passport / ID card / driver’s licence, selfie with the document and current date, residential address, e‑mail, phone, social media);
• request proof of funds (wallet withdrawal screenshots, blockchain links, correspondence, etc.).
5.2. If the Customer fails to provide the requested information within seven calendar days, the Service may refuse to process the order and, where possible, initiate a return to the sender’s address within seven banking days.
6. Funds Retention and Investigations.
6.1. Funds with high risk or under official investigation are retained until verification is completed or the investigation ends.
6.2. After successful verification, the Service may execute the order or refuse further service if an illegal purpose is established.
7. Verification Timeline.
7.1. The countdown starts once all required data are received from the Customer and usually takes ≤ 72 hours to complete.
8. Information Disclosure.
8.1. Customer data may be shared with competent authorities upon:
• official law‑enforcement request;
• court order;
• request from payment‑systеm administrators.
9. Policy Amendments.
9.1. The Service may unilaterally amend this Policy; the new version becomes effective upon publication at bullup.ai.
10. Acceptance of Policy.
10.1. By sending funds to a Service wallet, the Customer unconditionally agrees to this AML / KYC Policy.
