AML and transaction monitoring policy
We use transaction monitoring and risk controls to protect customers, the service and payment infrastructure. A normal exchange is not automatically sent to KYC, but a specific transaction may be paused when a real risk or compliance trigger is detected.
We do not serve users from Russia or Belarus. Other geographic restrictions may apply when required by applicable sanctions, legal restrictions or BULLUP service availability. These restrictions may be updated when those requirements change.
Transaction monitoring and holds
A deposit or payout may be paused when a security or compliance system detects unusual activity, restricted exposure or another risk that requires review. We wait for the final status before continuing the affected money flow and do not create a duplicate payout while an existing one is under review.
KYC, KYT and source of funds
We may request identity verification, transaction information, supporting evidence and source-of-funds information for a particular transaction or for the customer relationship when the review requires it. Until the requested information is reviewed, trading or payout may remain suspended.
What happens after a review
A review ends in one of the following general outcomes. If no blocking issue is confirmed, the affected money flow continues from its safe current stage. If BULLUP cannot continue the service but a return is permitted and technically possible, a funded order moves to a refund or manual-resolution flow. A return is based on the funds or assets actually available to BULLUP for return; if the original asset has already been converted, we do not promise an automatic buy-back of that asset. If an applicable legal or security restriction prevents an immediate return, the affected funds remain on hold until a lawful resolution is available. A review hold does not by itself mean automatic confiscation, and it is not a guarantee of release.
Address risk checks
The public AML address checker provides a current, time-specific risk assessment based on data available at the moment of the check. If the result is Low or Medium risk, the customer may send funds normally. Medium risk is not a block by itself. We do not process operations with addresses assessed as High risk. The result is not a permanent certificate of cleanliness and does not guarantee that a future transaction will be accepted automatically. Every incoming transaction remains subject to transaction-level monitoring. If a particular transfer is later confirmed to have a material restricted-risk connection, such as sanctions, stolen funds, fraud, darknet or other prohibited activity, the affected money flow is paused until the review is completed. The same rule applies when a payout is linked to such a risk.
Restricted sources and services
We do not process operations connected with the services and sources listed below. A risk connection may be direct or indirect, and its relevance is reviewed in the context of the particular transaction. We may take into account whether exposure is current or historical and whether it is material to the transaction; a distant historical interaction is not automatically treated the same as a direct current connection. Absence from the named list is not blanket approval, because every incoming transaction is still monitored. The list may be updated when our compliance requirements change.
Risk categories requiring enhanced review
Exposure to the following categories may result in a hold and additional verification depending on the transaction context.
Privacy-focused assets
Privacy-focused assets are not automatically blocked or sent to KYC solely because of the asset type. If a specific transaction triggers a real hold or risk review, additional information may be requested for that case.
Infrastructure confidentiality
When a transaction is paused by an external security, compliance, liquidity or payment service, we explain the status from BULLUP and do not disclose confidential infrastructure, internal correspondence, provider identities or provider-identifying materials.
Official requests and record retention
We may preserve and provide transaction-specific information when required by a valid official request and applicable law. Records relating to funded exchanges and customers are retained for at least five years from the first actual deposit, subject to applicable law and security requirements.