AML/KYC
Anti-Money Laundering and “Know Your Customer” Policy (hereinafter “AML/KYC Policy”) is intended to prevent and reduce possible risks of https://rubycash.org/ being involved in any illegal activities.
Definitions
Website / RubyCash – an online platform for the exchange of digital (electronic) currencies located at: https://rubycash.org/, as well as subdomains, APIs, and other informational resources belonging to RubyCash and related to this Website;
Services – digital (electronic) currency exchange procedures conducted on the Website: https://rubycash.org/;
User – any visitor to the Website. The User confirms that they are at least 18 years old, the laws of their country of residence do not prohibit the use of this Website, and that they do not intend to conduct any illegal activities through the use of the Website’s services;
Administration – authorized personnel to manage the Website, acting on behalf of the Website: https://rubycash.org/;
Personal data – any information related to an identified or identifiable individual (Personal Data Subject);
Application – submission by the User of an offer to buy or sell digital (electronic) currencies using the Services provided by the Website.
1. Purpose of Internal Regulation
1.1. The service https://rubycash.org/ adheres to practices and measures in the field of Anti-Money Laundering (AML) and combating the financing of terrorism. The goal of these measures is to demonstrate that RubyCash takes any attempts to use the Website for illegal purposes very seriously.
2. Warning
2.1. The service https://rubycash.org/ warns against attempts to use the Website for money laundering, terrorist financing, any form of fraud, and for purchasing prohibited goods and services. The Website, its Administration, employees, and domain owners are not responsible for the unlawful use of the service by third parties, malicious actions, and potential damage associated with the use of the Website.
3. Requirements
3.1. To prevent illegal transactions, the Website establishes specific requirements for all Applications created by the User:
3.1.1. The payer and recipient of the Application payment must be the same person. Transfers to third parties using the Website’s Services are strictly prohibited;
3.1.2. All contact information entered by the User in the Application, as well as other Personal Data transmitted by the User to the Website, must be current and fully accurate;
3.1.3. It is strictly prohibited to create Applications using anonymous proxy servers, VPN, Tor, or any other anonymous Internet connections;
4. Verification Procedures
One of the international standards for preventing illegal activity is proper customer verification (hereinafter – Verification). To this end, the Website implements its own verification procedures in strict compliance with Anti-Money Laundering standards and the “Know Your Customer” procedure.
4.1. The service https://rubycash.org/ may require the User to provide reliable, independent source documents, data, or information for verification and to confirm the sources of funds. The required documents may inсlude:
– A photograph of a document verifying the User’s identity (passport or national ID), showing all sides in good quality;
– A photograph of the User holding this document in their hand in good quality (selfie);
– Proof of the User’s employment status;
– A scan or photograph of the passport (first, second pages, and residence page in good quality);
– Proof of funds origin (photos, screenshots, statements);
– A video where the person who sent the funds, with an open passport in hand (clearly showing the photo, full name), states that they created the Application ID (Application number) at the exchange service https://rubycash.org/, the funds are their personal property, and they bear full legal responsibility for this cryptocurrency. The video should also mention the source of the funds;
– A video taken from the platform from where the funds were sent, showing the hash, sender and recipient addresses, amount with ticker, and transaction date. The video must be at least 10 seconds long.
4.2. The service https://rubycash.org/ does not support transactions with a risk level of 50% or above in any of the following high-risk categories: illegal service, mixing service, fraudulent, exchange, darknet marketplace, darknet service, ransom, scam, stolen coins, terrorism financing, sanctions, illicit actor/organization, high-risk jurisdiction, gambling, fraud shop, enforcement action, child exploitation.
4.3. The service https://rubycash.org/ strongly recommends contacting Website support to check the sender’s cryptocurrency address for AML before creating an Application to avoid potential blocking.
4.4. In case of blockage due to high risk, suspicious activity, or official investigation, funds will be held until verification or investigation is completed. For such purposes, the Website reserves the right to collect the User’s identification information to comply with the AML/KYC Policy.
4.5. The service https://rubycash.org/ will take steps to confirm the authenticity of documents and information provided by Users. All legal methods will be used to double-check the identification information, and the Website reserves the right to investigate cases where specific Users are identified as dangerous or suspicious.
4.6. The service https://rubycash.org/ reserves the right to continuously verify the User’s identity, especially if their identification information has changed or their activity appears suspicious (unusual for a specific User). Additionally, the service https://rubycash.org/ reserves the right to request updated documents from Users, even if they have previously passed authentication.
4.7. The User’s identification information will be collected, stored, shared, and protected strictly in accordance with the service’s Privacy Policy and applicable regulations.
4.8. After confirming the User’s identity, the Website may refuse to provide Services to the User if the Website’s Services are used for conducting illegal activities.
4.9. The service https://rubycash.org/ has regulatory requirements to verify the source of financial or cryptocurrency funds to ensure that the sources of funds used by Users for trading are legal.
4.10. The service https://rubycash.org/ strongly discourages splitting funds from one wallet into multiple Applications – (smurfing). This may be considered “suspicious activity” and the transaction may be blocked, even if past transactions from this wallet were not blocked.
4.11. The service https://rubycash.org/ reserves the right not to disclose the reason for blocking a transaction.
5. Responsible Officer
The person responsible for AML compliance is a person duly authorized by RubyCash to ensure the effective implementation and enforcement of the AML/KYC policy.
5.1. The responsibility of such an officer is to oversee all aspects of the Website’s anti-money laundering activities, including anti-money laundering and counter-terrorist financing, including, but not limited to, the following methods:
– collecting User identification information;
– creating and updating internal policies and procedures to complete, review, submit, and maintain all reports and records required under applicable laws and regulations;
– monitoring transactions and investigating any significant deviations from normal activities;
– implementing a record management systеm for proper document, file, form, and log storage and retrieval;
– regularly updating the risk assessment;
– providing law enforcement authorities with the necessary information as required by applicable laws and regulations.
5.2. The officer responsible for AML compliance has the right to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.
6. systеm Functions
The service https://rubycash.org/ performs many tasks related to compliance, including data collection, filtering, record-keeping, investigation management, and reporting. systеm functions inсlude:
– daily User checks for recognized “blacklists” (e.g., OFAC), aggregation of transmissions across multiple data points, placing Users on watch and deny lists, opening cases for investigation where necessary, sending internal messages, and completing mandatory reports where applicable;
– case and document management.
7. Behavior Analysis
The service https://rubycash.org/ verifies Users not only by verifying their identity but, more importantly, by analyzing their behavior in transactions. Therefore, the service https://rubycash.org/ relies on data analysis as a tool for risk assessment and suspicion detection.
8. Risk Assessments
The Website, in accordance with international requirements, applies risk assessment practices to combat money laundering and terrorist financing. By applying a risk assessment approach to anti-money laundering, RubyCash ensures that measures to prevent or reduce money laundering and terrorist financing are proportionate to the risks identified.
9. User Checks
If the Website Administration has reasonable grounds to suspect that the User is attempting to use the Website’s Services for money laundering or to conduct any other illegal operations, the Administration has the right to:
– monitor the entire transaction chain to detect suspicious transactions;
– suspend the User’s exchange operation for the duration of the investigation, which may last up to 7 business days, or in special cases up to 30 business days;
– request identification documents from the User;
– request any additional information and documents from the User in the event of suspicious transactions;
– ensure that reports on suspicious transactions are submitted to the appropriate law enforcement agencies through the officer responsible for AML compliance.
9.1. Based on the investigation results, the Website Administration decides to either proceed with the exchange or return the funds (minus the sending fee), depending on the investigation’s outcome.
9.2. The refund or exchange, if approved, will be processed by the Administration within 7 (seven) calendar days from the date the User is notified of the Administration’s decision regarding their refund or exchange request.
9.3. Following the AML analysis of the transaction, if it is decided to exchange currency for the User, the rate may be recalculated at the current rate regardless of the chosen rate.
9.4. When processing a refund or exchange after verification, the User must confirm the details for receiving the refund or exchange.
9.5. In cases where law enforcement agencies are interested in the User’s transaction, the investigation period may be unlimited.
10. Confidentiality
The service https://rubycash.org/ guarantees User confidentiality in accordance with the Website’s Privacy Policy.
10.1. The Website and its employees are obligated to maintain confidentiality regarding any facts discovered in connection with any suspicious transaction. This obligation also applies to Website Users and third parties who were provided with information about the transaction.
10.2. The confidentiality obligation imposed on the employees of the Website https://rubycash.org/ remains in effect after their employment or any other contractual relationship with the service https://rubycash.org/ ends, and upon transfer to another workplace. Disclosure of such information to government, law enforcement authorities, and other entities in cases defined by law is not considered a breach of confidentiality obligations.
10.3. The confidentiality obligation, provided that the use of the disclosed information is limited to preventing the legitimization of criminal proceeds and financing terrorism, does not apply to the disclosure of information between financial institutions that form a consolidated group in cooperation with the service https://rubycash.org/.
11. Conclusion
In light of the above, the service https://rubycash.org/ bears no legal responsibility for its use in money laundering, financing terrorism, or purchasing prohibited goods and services. However, it commits to taking all possible and available measures to prevent attempts to use the service https://rubycash.org/ for money laundering, financing terrorism, or purchasing prohibited goods and services. By making an exchange, the User agrees with all terms of these policies and agrees to comply with them according to the exchange rules in effect at https://rubycash.org/.