Anti-Money Laundering and Customer Due Diligence (AML/KYC) Policy
This AML/KYC/KYT Policy defines the principles and procedures applied by Vilcov.com (hereinafter referred to as the "Service"). The purpose is to prevent the use of the Service for money laundering, terrorist financing, sanctions evasion, fraud, money laundering (including ransomware, malware), receiving payments from darknet platforms, crypto mixers, and other illegal activities.
By using the Service, the User confirms that:
- their funds were obtained legally;
- they do not use the Service for illegal transactions;
- they agree to this AML Policy.
The Service applies a risk-based approach to cryptocurrency transactions. Each transaction may be checked automatically and manually using AML analytical tools, the Service's internal rules, and the rules and algorithms of connected partner websites.
Based on the transaction analysis results, the Service makes a decision on processing, suspension, additional verification, or refund. These are international standards for accepting and processing payments.
1. Terms and Abbreviations
AML (Anti-Money Laundering) — measures to combat money laundering.
KYC (Know Your Customer) — identification and verification of the User.
KYT (Know Your Transaction) — analysis and monitoring of transactions, including the origin of funds.
SoF (Source of Funds) — confirmation of the source of funds.
EDD (Enhanced Due Diligence) — enhanced verification for increased risk.
Risk Score — an estimated risk score for a transaction/address based on blockchain analytics and other risk indicators.
Sanctioned Connection — direct or indirect connection with sanctioned individuals, organizations, or jurisdictions.
2. Monitoring Tools Used
To analyze transactions in real time and identify suspicious payments, the Service uses blockchain analytics software: Chainalysis, Crystal Intelligence, Elliptic, Scorechain, AMLBot, and other licensed KYC systems, as well as transaction monitoring systems (TMS) to identify unusual transfer patterns. The risk level is determined based on the combined data from these systems.
3. Risk Assessment Model (Risk-Score)
The system evaluates each transaction based on multiple factors, including the wallet history and its connections.
Low Risk (up to 50%): The request is processed automatically.
High Risk (50–75%): The transaction may be suspended for further analysis by a compliance specialist.
High Risk (75%+): Exchange transaction may be suspended. High-risk categories include: Enforcement Action; Fraudulent Exchange; Terrorist Financing; Child Abuse/Human Trafficking; Black Market Services; Illegal / Crime-Related Activities; Scam / Fraud; Mixer / Tumbler / Privacy Tools; Malware / Ransom; Stolen Funds / Hack / Exploit; Drainer Wallets; Blackmail / Sextortion; Ponzi / HYIP.
4. Pre-AML Check
Before conducting an exchange transaction, the User can contact the Service's support team to conduct a preliminary AML check of their cryptocurrency address. This check assesses the risk level of the assets and determines the likelihood of possible transaction suspension. Based on the analysis results, the User may be informed of the estimated risk level of the assets and the feasibility of the exchange transaction.
We recommend using the preliminary check before an exchange, as it minimizes the risk of transaction suspension or blocking during the AML check.
Alternatively, the User can independently conduct an AML check of their wallet using specialized blockchain analytics services, in particular the AML reporting service available on the Bestchange.com/report platform.
5. KYC Procedure
If a transaction is deemed to be of high risk, the Service may request that the client complete the KYC (Know Your Customer) procedure.
During the check, the following may be requested:
- Identity document (passport, ID card, driver's license)
- Selfie with the document
- Video verification
- Proof of residential address
- Proof of Funds (SoF)
- Screenshots of transaction history
- Proof of cryptocurrency wallet ownership
The Service reserves the right to request additional documents if necessary.
6. AML Check Timeframes
The standard check timeframe is 1 to 72 hours.
In complex cases, the check may be extended to 7 business days.
The user is obliged to provide the requested documents within 5 days.
7. The service reserves the right to suspend a transaction in the following cases:
- a high Risk Score
- suspicion of illegal origin of funds
lack of necessary information from the user
In such cases, funds may be temporarily held until verification is completed
8. Refunds
If the transaction is refused, funds may be returned to the user's sending address The refund is processed after AML/KYC verification procedures are completed.
The refund fee may be up to 5% of the transaction amount, but no more than the equivalent of $100. For bona fide users whose funds are not confirmed as being related to illegal activity after verification, only the blockchain network fee is withheld.
9. Information Sharing
The Service may share transaction and user information with law enforcement agencies upon official request and with other authorized bodies in accordance with the law.
10. Information Storage
Transaction and verification information may be stored by the Service for up to 3 years to comply with AML control requirements and prevent financial crimes.
https://vilcov.com/workterms.php#p0
What should I do if I have been contacted by the police about interacting with your website?
A typical question from a client sounds like this - the police came to me, started asking questions, ruined the whole day, what should I do? Our lawyer answers:
- They came to the client without a summons. Real police officers must present a properly executed subpoena with a wet police seal, indicating the case number (a real case, not a fictitious one - this can be verified later) signed by the officer, indicating the article and sub-section under which the investigation is being conducted.
- The client did not copy the data of the employee's certificate: full name, position, number, having the right to do so.
- The client began to testify without a lawyer. Every citizen has the right to use the services of a lawyer. On the basis of his certificate, the lawyer has the right to familiarize himself with the case materials. Only a lawyer will allow to stop illegal questions and exclude pressure from the authorities.
- The client did not use Article 63 of the Constitution of Ukraine. This article gives a person the right not to testify against himself. Any citizen has the right to legally refuse to answer any question, using the following: "I refuse to testify, in accordance with Article 63 of the Constitution of Ukraine."
- The client has the right to refuse previously provided testimony. For this, a complaint is written to the prosecutor's office through a lawyer about the actions of the police officer(s), arguing that the summons, interrogation, and pressure are illegal. We are ready to provide samples of such statements.
Also, we are always ready to provide our lawyer to help clients or to pay your lawyer in such cases.
It happens that the client did not have the opportunity to ask on what basis access to his bank account was obtained . After all, the access was obtained illegally, without any court decision. If there is a court decision to disclose bank secrecy, then the lawyer has the right to get acquainted with such a document.
In Bestchange, you can find out the bank card number of any exchanger. Some employees of the authorities, abusing their official position, can gain access to bank accounts and even "sell" this information. It is our civic duty to record such manifestations of corruption and to direct complaints to the appropriate authorities. There is nothing criminal in the fact that one private person (the exchanger) transfers funds to another private person (the recipient).
https://vilcov.com/workterms.php#p12
User Agreement
1. General terms and conditions
1.1 This agreement sets out the terms and conditions for the provision of services by vilcov.com.
1.2 The vilcov.com Administration is the person or persons providing access to the vilcov.com service.
1.3 The Client is a person who wishes to use the vilcov.com services.
1.4 vilcov.com and the Client are jointly referred to as the Parties.
1.5 By using the Site, registering an account or using vilcov.com's services, you agree that you have read, understood and accepted all the terms and conditions contained in this Agreement and the Privacy Policy.
1.6 This Agreement is considered to be concluded on the terms of a public offer accepted by the Client when placing an order on the vilcov.com website for the use of the Services.
1.7 If you do not agree to the terms of this Agreement, you are not permitted to use the vilcov.com website.
2. Subject of the Agreement
2.1 vilcov.com provides the Client with services (see point 4 of the Agreement) in accordance with the regulations (see point 5 of the Agreement), subject to the mandatory conditions (see point 9 of the Agreement).
2.2 The Client uses and pays for vilcov.com's services in accordance with the terms of this Agreement.
3. Rights and obligations of the parties
3.1 vilcov.com is obliged to:
3.1.1 exchange electronic currencies (Tether USDT, Bitcoin, USD and EUR) and other payment systems at the Client's request. The procedure for providing such services is regulated by the terms of this Agreement. The Administration may reduce or supplement the list of electronic currencies available for exchange at any time.
3.1.2 Provide the Client with advice and assistance in resolving technical problems to ensure the proper provision and use of exchange services.
3.1.3 All information relating to customer exchange transactions (wallet addresses, amounts, times, personal data, etc.) should be stored and made available to customers upon request, except for transactions involving anonymous payment systems.
3.1.4 Keep information on exchange transactions and the personal data of vilcov.com customers confidential and do not disclose it to third parties, except in the following situations:
- upon lawful court decision at the location of the vilcov.com service owner
- upon lawful request from the relevant authorities at the location of the vilcov.com service owner.
3.1.5 Transfer funds to clients according to the specified details no later than 48 hours after they complain about non-arrival of funds following an exchange, in cases described in points 3.2.5, 5.1.4, 5.1.5 and 5.1.6 of this agreement.
3.2 The Client is obliged to do the following:
3.2.1 When placing an order for an exchange, provide accurate and reliable payment details.
3.2.2 Provide an accurate and valid email address.
3.2.3 Monitor the performance of your email account and computer, and ensure you are using up-to-date antivirus software.
3.2.4 Comply with all the rules of this Agreement. Comply with all the rules of this Agreement.
3.2.5 Notify vilcov.com administration if you do not receive funds after an exchange operation to the specified account, but no later than three days after ordering the service. If you fail to do so, or if you do so after the deadline, the money received becomes the property of the vilcov.com administration. The basis for submitting a complaint is specified in paragraphs 5.1.4, 5.1.5 and 5.1.6.
3.2.6 When applying for an exchange, provide the correct and valid mobile number when requested. The client is responsible for keeping confidential any information received from the service operator and stored on their smartphone. The client must ensure that third parties do not have access to their device.
3.2.7 By carrying out exchange transactions using the vilcov.com service, they shall not violate the current legislation of the country in which the Client is located.
3.2.8 If a larger amount is credited to the Client's account than specified in the order due to unforeseen circumstances (e.g. operating system error), the Client must return the extra funds to vilcov.com.
3.3 The vilcov.com administration may:
3.3.1 to suspend the service for technical upgrades or to eliminate functional errors.
3.3.2 To suspend the current exchange (transaction) in the case of a legitimate request from the relevant authorities or users complaining of fraud, while the circumstances are being clarified.
3.3.3 Offer discounts to users of exchange services.
3.3.4 Establish and change the amount of commission charged to clients for the exchange of electronic money at the Administration's discretion.
3.3.5 Refuse to provide services to any client without explanation.
3.3.6 Check the origin of any cryptocurrency offered for exchange. If any suspicious transactions are detected (at the discretion of the vilcov.com administration), refuse to complete the exchange transaction for the client and return all funds received from the client in full, minus the system fee.
3.3.7 Require the client to confirm their affiliation with the electronic exchange by providing:
- email;
- screenshot of the electronic wallet;
- if necessary, a verification call to the phone number specified when filling out the exchange form from which the funds were sent for the electronic exchange (if this exchange ended in error).
3.3.8 Stop correspondence or negotiations with the Client if they are rude, use obscene language or insults, ask questions unrelated to the vilcov.com support service, or do not answer questions from the support service.
3.3.9 Block the exchange in accordance with points 5.1.4, 5.1.5 and 5.1.6 of the electronic money exchange regulations.
3.3.10 Do not return funds to the client until their identity has been established (if necessary).
4. Procedure for providing vilcov.com services
4.1 Users access the service by placing an order via the website.
4.2 By using the Service, the User confirms that they legally own, use and dispose of the cryptocurrency, electronic money or fiat currency involved in the relevant payment.
4.3 The Service does not provide exchange services to users whose bank cards or accounts do not belong to them. The Service does not enter into partnership relations with trade and service enterprises, nor is it an agent in mutual settlements regarding any agreements between the User and third parties.
4.4 Within the time allotted by the regulations, from the moment of receiving the cryptocurrency, electronic money or fiat currency from the user in the amount specified in the relevant order, the service is obliged to transfer the received cryptocurrency, electronic money or fiat currency to the details and in the amount specified by the user in the order.
4.5 The Service reserves the right to issue a refund in USDT at the current exchange rate of the Payment System, minus the fee charged by the Payment System during the refund process.
4.6 If the exchange rate changes during processing of the order, the service will recalculate the order at the exchange rate at the time the cryptocurrency is received into the account, or will refund the funds minus the payment system fee charged during the refund process.
4.7 If the user has paid for an order but then wishes to cancel it, the refund will be made minus the relevant payment system's commission.
4.8 If the Service detects suspicious activity during the User's order process, it has the right to suspend such operations until the reasons for such activity are clarified, in order to avoid damage.
4.9 The Service reserves the right to refuse to provide services to a User who fails to provide the complete and sufficient identification data required, and to block funds received from such a User until this data is provided.
4.10 The Service has the right to cancel the exchange if it suspects that the User received the Funds as a result of illegal activity, in accordance with the legislation of the country in which the Service is located or the country of which the User is a resident.
5. Regulations for the exchange of electronic money
5.1 General rules for exchanging currencies on the site:
5.1.1 The exchange is considered to have started when vilcov.com receives the full amount intended for exchange from the client.
5.1.2 The exchange is considered complete when vilcov.com transfers the assigned amount to the client's specified payment details.
5.1.3 Exchanges of electronic money cannot be cancelled once they have begun, nor can funds that the client intended to exchange be returned to them.
5.1.4 If the Client recalculates an amount other than that specified in the exchange order, the Operator has the right to recalculate the amount actually received. If this differs by more than 10% from the declared amount, the operator has the right to cancel the order unilaterally. In this case, the funds received by the Operator shall be returned to the Client. In the case of a reverse transfer, all fees shall be paid by the client.
5.1.5 If the Client specifies non-existent or blocked details to which the amount should be received as a result of the exchange, vilcov.com may suspend the exchange. After the Client's request in accordance with point 3.2.5, vilcov.com may return the funds to the account from which they were received. In this case, the Client must pay the payment system fee. If it is impossible to send funds to the specified details for other reasons, the Client must provide new details to which vilcov.com will send the funds. In the absence of such details, the funds may be returned to the Client's account in full, minus the system fee.
5.1.6 If the order is paid by a third party, the exchange may be blocked. After the Client's request, the exchange amount will be refunded, minus the payment system commission, in accordance with point 3.2.5.
5.1.7 Taking into account point 5.1.1, the maximum time for crediting funds to bank cards may be 72 hours, due to standard banking practice in complex cases.
5.2 Cryptocurrency exchange regulations:
5.2.1 When buying or selling Bitcoin and other cryptocurrencies for cash, the order must be paid for within 3 hours of its creation. Otherwise, vilcov.com operators have the right to cancel the order and require the client to place a new one on the website.
5.2.2 When exchanging Bitcoin and other cryptocurrencies for any other currency, the phone number specified in the exchange details must correspond to the client's personal phone number and be available for incoming calls.
5.2.3 When exchanging Bitcoin automatically with withdrawal of funds to bank cards, the cryptocurrency rate is fixed when the transaction appears in the Bitcoin blockchain and the funds are sent after the third confirmation by the network.
5.2.4 When exchanging USDT (TRC20) automatically with withdrawal to bank cards, the cryptocurrency rate is fixed when the transaction appears in the blockchain. This means that, as soon as the USDT transaction is confirmed on the TRON network (21 confirmations), the exchange rate will be fixed and the amount in hryvnia that you will receive on your bank card will be calculated at this rate, regardless of any subsequent fluctuations in the exchange rate.
6. Responsibilities of the parties
6.1 The Administration of vilcov.com is not responsible for, nor will it compensate for, any losses incurred due to the improper (unauthorised) use of the Service, or errors made by the Client when filling out the exchange form. Such errors may lead to the transfer of funds to an erroneously specified account, in which case it will be impossible to cancel the exchange operation or return the funds.
6.2 vilcov.com is not liable for any loss and/or damage arising from the client's inability to use their own equipment and/or its elements, or the lack of full or partial functionality of the equipment or its elements.
6.3 vilcov.com is not responsible for errors, omissions or delays in payments made by electronic payment systems and banks.
6.4 vilcov.com reserves the right to set an exchange rate favourable to the company at any given time. This exchange rate may or may not coincide with rates on known and widely used currency exchanges.
6.5 vilcov.com reserves the right to recalculate the exchange rate for an order that was previously processed at the time of payment for the order.
6.6 vilcov.com reserves the right to refuse payment to clients under the affiliate programme if the vilcov.com system detects that they have used this opportunity to receive a discount on their own exchange (i.e. if the order was made from the same IP address).
7. Change of information
7.1 This agreement may be amended and supplemented by vilcov.com; any changes will take effect from the moment the agreement is published on vilcov.com.
8. Force majeure
8.1 Neither Party shall be liable for any delay or failure to perform their obligations under this Agreement and/or other agreements if such delay or failure is caused by circumstances beyond their control, including (without limitation) natural disasters, acts of government or regulatory authorities, war, fire, flood, explosion, terrorism, riot, civil unrest, hacker attacks, absence of, or failure in, energy supplies, internet services, communication networks or other systems, networks and devices.
9. Mandatory conditions for conducting exchange transactions:
9.1 Using the vilcov.com service to carry out illegal transfers and fraudulent actions is prohibited. By using vilcov.com, the Client agrees that any attempt to exchange funds of dubious origin will be prosecuted in accordance with the current legislation of the country in which the Client is carrying out exchange operations.
9.2 The vilcov.com service administration reserves the right to provide information about such payments to the relevant authorities, payment system administrations and victims of fraud, if illegal activity is proven.
9.3 The exchange is based on the principle that the Client withdraws currency only from their source wallet when using the vilcov.com service. The Client is responsible for the source and methods of receipt to their electronic wallet, given that the vilcov.com service has the ability to check their origin.
9.4 Vilcov.com is not responsible for exchange transactions made on behalf of the Client in favour of third parties.
9.5 The vilcov.com service does not cooperate with citizens of the Russian Federation.
9.6 By clicking the 'I agree with the terms of the Service' button, the Client confirms their acceptance of all requirements under this Agreement.
https://vilcov.com/workterms.php#p13
