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AML & KYC

AML & KYC Policy

Version 1.0 · Last updated 11 June 2026

mSamex operates a risk-based program to deter money laundering, fraud and other financial crime. 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.

Your acknowledgement. By using the Platform you agree to comply with this Policy and consent to the verification, screening, monitoring, holds, reporting and enforcement actions described below. We may apply these measures at any time, at our discretion, with or without notice, and without liability.

1. Identity verification (KYC)

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, or politically exposed persons (PEPs), 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. Open access — no country restrictions

2.1. mSamex does not designate any country as a restricted or prohibited territory and does not block access on the basis of nationality, residence or geographic location. The Platform is intended to be open to users worldwide.

2.2. You remain solely responsible for ensuring that your own use of the Platform is lawful in your location. Our checks target fraud and financial crime at the level of individual conduct — not the exclusion of any country, nationality or community.

2.3. We do not geo-block by country. We may still act against any individual account for fraud, cheating, abuse or breach of these policies as described below.

3. Source of funds & tainted assets

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, mixer-obscured, "tainted", blacklisted or high-risk sources, and may decline to facilitate Trades with counterparties that fail screening.

4. Transaction monitoring

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. Our rights to act

5.1. Where we identify or suspect, in our reasonable judgement, a breach of this Policy, fraud, cheating, 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.

6. Reporting & no tipping-off

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.

7. Cooperation & your obligations

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.

8. Record keeping

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.

9. Changes

We may update this Policy at any time by posting a revised version. Continued use after changes take effect constitutes acceptance.

10. Contact

Compliance matters: compliance@msamex.com · mSamex OÜ, Tallinn, Estonia.

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