mSamex operates a risk-based program to deter money laundering, terrorist financing, sanctions evasion and fraud. This Policy summarises the rules that apply to your use of the Platform and the rights we reserve to verify, monitor, restrict, freeze, block and report. It forms part of our Terms of Service.
1.1. We apply customer due diligence on a risk-based basis. We may require you to verify your identity before or during use of the Platform, including before raising limits, withdrawing, or completing a Trade. Verification may include collecting your legal name, date of birth, nationality, address, government-issued ID, a selfie/liveness check, and confirmation of wallet ownership.
1.2. We may apply enhanced due diligence for higher-risk Users, larger volumes, unusual patterns, politically exposed persons (PEPs), or higher-risk jurisdictions, including requests for proof of source of funds or wealth.
1.3. We may use third-party verification providers. You must provide accurate, genuine, current documents. We may refuse, suspend, limit or terminate access where verification is incomplete, refused, expired, or appears false or fraudulent.
2.1. You may not use the Platform if you are, or act for, a person or entity that is: (a) subject to sanctions by the United Nations, European Union, or other applicable authorities; (b) listed on any applicable sanctions, terrorism or watch list; or (c) located in or ordinarily resident in a Prohibited Jurisdiction we designate from time to time.
2.2. We screen Users, wallets and transactions against sanctions and watch lists and may block, freeze, reject or report any matched or suspected activity and the persons involved.
2.3. We may use IP geolocation and other signals to restrict access from jurisdictions where the Platform is prohibited or where we choose not to operate, and you must not attempt to circumvent such restrictions.
3.1. You represent that all funds and crypto-assets you use are lawfully yours and are not derived from, or intended for, unlawful activity.
3.2. We use blockchain analytics and "freeze-protection" screening to assess the risk of crypto-assets and counterparties. We may reject, hold, flag or unwind dealings involving crypto-assets that are, or are linked to, stolen, sanctioned, mixer-obscured, "tainted", blacklisted or high-risk sources, and may decline to facilitate Trades with counterparties that fail screening.
We monitor activity on the Platform for indicators of money laundering, fraud, cheating, structuring, collusion, account takeover, multi-accounting and other abuse. We may use automated and manual review, set thresholds and limits, and investigate any Account, wallet, Trade, payment or pattern of activity.
5.1. Where we identify or suspect, in our reasonable judgement, a breach of this Policy, fraud, cheating, sanctions exposure, or other prohibited or unlawful activity, we may, at our sole discretion, with or without notice and without liability:
5.2. You agree we are not required to prove suspected misconduct to any legal standard before acting, and you waive, to the maximum extent permitted by law, any claim arising from action taken in good faith under this Policy.
Where required or appropriate, we file reports with competent authorities. We may be legally prohibited from informing you that a report has been made or that an investigation is underway, and we may decline to give reasons for an enforcement action where disclosure could prejudice an investigation or breach law.
You must cooperate promptly and truthfully with any request, investigation or verification. Providing false information, forged documents or fabricated evidence is a serious breach and may result in immediate termination and reporting.
We retain identity, verification, transaction and screening records for the periods required by applicable anti-money-laundering law (generally at least five years), as described in our Privacy Policy.
We may update this Policy at any time by posting a revised version. Continued use after changes take effect constitutes acceptance.
Compliance matters: compliance@msamex.com · mSamex OÜ, Tallinn, Estonia.