GOLDEN EXCHANGE
RUEN

AML policy

Version of 28 July 2026

This policy describes the measures Golden Exchange applies against money laundering and terrorist financing. It forms part of the service rules. In case of any discrepancy the Russian version prevails.

1. Principles

  • 1.1. The service does not handle transactions connected with criminal activity and does not take part in schemes that conceal the origin of funds.
  • 1.2. Measures are applied in proportion to the risk of the particular transaction. A review is not a routine step and is not applied to every order.
  • 1.3. A suspension always has a specific ground, timeframe and outcome, of which the client is notified.

2. Signs of elevated risk

  • 2.1. A link between the address or the funds and known cases of theft, extortion or trade in prohibited goods, or with services designed to conceal the origin of funds.
  • 2.2. A link between the client, the address or the payment details and applicable sanctions.
  • 2.3. Amount splitting, a series of similar orders, or signs that orders are being created automatically.
  • 2.4. Payment from an account or wallet that does not belong to the client.
  • 2.5. Reasonable information that the client is acting under deception by third parties.
  • 2.6. Other circumstances giving reasonable grounds to doubt the lawfulness of the transaction.

3. Measures

  • 3.1. The service may use third-party blockchain analytics to assess the risk of incoming funds and of the receiving address.
  • 3.2. Where signs of elevated risk are found, execution of the order is suspended until the review is complete.
  • 3.3. The service may ask the client to explain the origin of the funds, to confirm ownership of the account or wallet the payment came from, and to provide an identity document.
  • 3.4. Only what is necessary to review the particular transaction is requested.

4. Timeframes

  • 4.1. A review takes up to 30 calendar days from the suspension.
  • 4.2. If the requested information is not provided within 14 calendar days of the request, the review is closed with a negative outcome.
  • 4.3. The client is notified of the outcome through support.

5. Outcome of a review

  • 5.1. Where the doubts are resolved, the order is executed on the terms of section 5 of the service rules.
  • 5.2. Where the risk is confirmed, the service refuses the transaction. Funds are returned to the sender details less the network fee and actual costs.
  • 5.3. No refund is made where it is directly prohibited by applicable law or where the sender details are not available for a return.
  • 5.4. The service may refuse further service to the client.

6. Review data

  • 6.1. Information and documents obtained during a review are used solely for the purposes of this policy.
  • 6.2. They are retained for no less than the period applicable law sets for records of financial transactions.
  • 6.3. Information is disclosed to third parties only on grounds provided by law.

7. Updates

  • 7.1. This policy is reviewed as legislation and practice change. The version in force is published on this page with its date.