Anti-Money Laundering Policy (AML Policy).

NewLine warns users against attempting to use the service for laundering proceeds from criminal activity, financing terrorism, engaging in any illegal activities, as well as using the service to purchase prohibited goods and services.

Money laundering is the concealment of the illegal origin of funds by converting them into legitimate-looking money or investments.

All transactions conducted through the service are subject to mandatory automatic AML checks.

General Provisions

To prevent illegal activities, the Service establishes certain requirements for all Listings created by the User:

1. In the created Listing, the Sender and the recipient of the Payment must be the same person. Transfers to third parties are strictly prohibited.

2. All contact details provided by the User must be accurate and up-to-date.

3. The use of anonymous proxy servers and other methods of concealing identity is prohibited.

4. All transactions are subject to mandatory AML checks.

AML Check and Risk Assessment

The NewLine service uses specialized AML services (e.g., BitOk or similar) to analyze:

cryptocurrency addresses;

transactions (TXID);

sources of funds.

Based on the analysis, a Risk Score is generated — an assessment of the transaction's risk level.

0–30% — low risk: the transaction is processed automatically.

30–60% — medium risk: the transaction may be paused for review.

60% and above — high risk: the transaction is blocked, and the KYC/SoF procedure is initiated.

High-risk transactions include those associated with:

darknet;

mixer/tumbler services;

sanctioned addresses;

stolen funds;

fraud and other sources;

classified as High Risk.

AML Policy

1. Do not engage in business relationships with known criminals and/or terrorists.

2. Do not process transactions related to criminal activities.

3. Do not facilitate illegal transactions.

4. The service reserves the right to restrict or prohibit the use of all or part of the services for citizens of countries such as Afghanistan, Uzbekistan, Bosnia and Herzegovina, USA, North Korea, Tajikistan, Democratic Republic of Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, Laos, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine.

5. The service reserves the right to update this list in accordance with international requirements and internal risk assessment.

Verification Procedures

The NewLine service establishes its own verification procedures within the standards for combating money laundering — the "Know Your Customer" (KYC) policy.

Verification may include the following steps:

automatic AML transaction check;

user notification of verification requirement;

document request;

KYC procedure;

confirmation of source of funds (SoF);

decision on the transaction (completion / refund / rejection).

The NewLine service may require verification (providing an identity document: passport or ID card).

Additionally, the NewLine service may request a second document to identify the User: a bank statement or utility bill not older than 3 months, showing the User's full name and actual residence.

Additionally, the service may request:

screenshots of the cryptocurrency wallet;

transaction history;

proof of source of funds;

photo/video verification of the client.

NewLine reserves the right to collect Users' identification information for the purposes of implementing the AML Policy. This information is processed and stored strictly in accordance with the Privacy Policy and NewLine's Personal Data Processing Policy.

NewLine verifies the authenticity of documents and information provided by Users and reserves the right to obtain additional information from Users identified as suspicious.

If the User's identification information has changed or their activity appears suspicious, NewLine has the right to request updated documents from the User, even if they have previously passed verification.

Conditions for Suspension and Refund of Funds

In case of a heightened risk level or suspicious activity, the NewLine Service reserves the right to suspend the exchange until the circumstances are clarified.

Refunds are carried out under the following conditions:

If, after verification, the funds are not associated with illegal activity and the User has successfully completed KYC/SoF:

funds will be returned to the sender;

only the network fee (blockchain fee) is deducted;

no additional service fees are charged.

The refund period is usually from 1 to 5 business days from the completion of the verification.

If the User refuses to undergo verification, the refund period may be extended.

If the illegal origin of funds is confirmed, the service reserves the right to refuse the refund and transfer information to competent authorities.

AML Compliance Officer

The AML Compliance Officer is an employee of NewLine, whose duties include ensuring compliance with the AML policy, namely:

collection of Users' identification information and transfer to the responsible agent for personal data processing;

creation and updating of internal policies and procedures;

monitoring transactions and analyzing deviations;

implementation of document and data storage systems;

regular updating of risk assessment.

The AML Compliance Officer has the right to interact with law enforcement agencies.

Transaction Monitoring

User transaction monitoring is a tool for risk assessment and detection of suspicious activities.

In case of suspected money laundering, the NewLine Service reserves the right to:

report suspicious transactions to the relevant authorities;

request additional documents and information;

suspend or terminate service;

freeze funds until circumstances are clarified;

refund funds to the user;

apply the internal risk assessment system (Risk Score).

Risk Assessment

In accordance with international requirements, the NewLine Service applies a risk-based approach (Risk-Based Approach) to combat money laundering and terrorist financing.

Control and verification measures are applied proportionally to the risk level of a particular transaction.