AML Policy
AML policy
Publication and Effective Date: June 18, 2026
By using the FlyPay Service (hereinafter referred to as the “Service”) and/or creating an exchange request, the User confirms that they have read this AML Policy (hereinafter referred to as the “Policy”) and agree to its terms.
The Service adheres to standards and implements measures aimed at preventing money laundering (AML — Anti-Money Laundering), counter-terrorist financing (CFT), sanctions evasion, fraud, and other illegal activities.
The purpose of these measures is to prevent the use of the Service for unlawful purposes and to ensure a high level of compliance.
1. Terms and Definitions
AML (Anti-Money Laundering) — measures to prevent money laundering.
EDD (Enhanced Due Diligence) — enhanced due diligence in cases of elevated or high risk.
KYC (Know Your Customer) — identification and verification of the User.
KYT (Know Your Transaction) — monitoring and analysis of transactions, including verification of the source of funds.
Risk-Score — an assessment of the risk level of a transaction or address based on AML analytics data and other factors.
SoF (Source of Funds) — confirmation of the origin of funds.
Sanctions Exposure — the presence of a direct or indirect connection between a transaction, address, or source of funds and sanctioned entities according to analytics data and sanctions lists.
2. Blacklisted Platforms and Services
The Service does not interact with certain platforms and services. Before creating a request, the User must ensure that the funds being sent, as well as the platforms or services used to send them, are not associated with those listed below.
Transactions related to the following resources are subject to blocking and will not pass AML checks: OMG!OMG!, MEGA DARKNET MARKET, 1xBit, Black Sprut, FreeBitcoin, Primedice, Stake, Hydra, Wasabi, DuelBits, WEX Exchange, Garantex, NVSPC, Tornado, Gandhiji.io, DuckDice, Roobet, Bitzlato, Yolo Group, Chiper Mixer, BTC-e, any cryptocurrency mixers and resources included in publicly available sanctions lists.The list of prohibited platforms and services may be updated. The User is responsible for independently monitoring the current version of the Policy on the website.
3. AML/KYT Tools Used
To analyze transactions and sources of funds, the Service uses specialized blockchain analytics tools, including but not limited to:
AMLBot;
other AML/KYT services and analytical solutions (depending on the network, asset, and verification scenario).
4. Risk-Score and Risk-Based Approach
The Service applies a risk-based approach: it assesses risks related to the User, transaction, and source of funds, and depending on the results, applies standard or enhanced verification procedures (KYC/SoF/EDD), suspends operations, or refuses service.
To assess the risk of each cryptocurrency transaction or address, a Risk-Score model is used, based on blockchain analytics data, historical address connections, and other risk indicators.
Risk-Score thresholds:
Low Risk: 0–25% — standard processing;
Medium Risk: 25–50% — temporary suspension for additional verification;
High Risk: 50% and above — the operation is blocked for AML control and KYC/SoF procedures (EDD if required).
The Risk-Score value may change over time due to updates in analytical data.
5. Verification Process
If Risk-Score thresholds are exceeded, AML triggers are activated, sanctions exposure is detected, or other high-risk factors are identified, the Service may initiate a verification procedure, including:
temporary suspension of the operation until verification is completed;
requesting data and documents within the framework of KYC/SoF;
analysis of the provided materials and transaction history;
decision-making: completion of the exchange or refusal with possible refund of funds.
The Service reserves the right not to disclose details of internal compliance assessments and the reasons for specific triggers if required for legal compliance, prevention of abuse, or upon request of authorized authorities.
6. Requested Materials (KYC/SoF)
Depending on the risk level and nature of the operation, the Service may request (non-exhaustive list):
an identity document (passport / ID card);
a selfie (including a selfie with the document) and/or photo or video verification;
proof of address (utility bill, bank statement, or other document);
proof of source of funds (SoF): statements, screenshots, transaction links, transaction history, explanations, etc.
Failure to provide the requested data or provision of inaccurate/incomplete information may result in suspension of the operation, refusal of service, or refund of funds (if applicable).
7. Verification Timeframes
Verification timeframes depend on the level of risk and completeness of the provided data:
standard verification — from 1 to 7 business days from the receipt of all documents;
enhanced verification (EDD/SoF) — from 30 to 60 calendar days in cases of high risk or complex transaction structures.
Timeframes may be extended due to delays on the User’s side or the need for additional analysis.
8. Refund Terms and Timeframes
If the exchange cannot be completed as a result of AML/KYT verification, the Service reserves the right to initiate a refund to the sender, subject to applicable law.
Refund conditions:
refunds are made to the original sender’s details and are not sent to third-party addresses;
the Service fee is not charged if the User has provided all the necessary information, only the network fee is charged, the amount of which depends on the blockchain network;
if the User has not provided the necessary information or has refused to undergo AML/KYT verification, and a refund is possible, the Service fee may be 5% (maximum 100 USDT) of the exchange amount, and the network fee is also charged, the amount of which depends on the blockchain network;
the refund period usually ranges from 1 to 5 business days after the decision is made and verification is completed.
9. User Responsibilities and Risk Acknowledgment
Before creating a request, the User must independently assess the risks associated with the origin of funds, including checking addresses and transactions for AML compliance, and ensure there is no connection with prohibited resources.
The Service recommends conducting independent AML checks in advance using publicly available tools and blockchain explorers.
By creating a request, the User confirms that they:
have independently assessed the risks of using the funds;
have verified the absence of connections with prohibited services;
understand the possibility of the transaction being classified as high-risk;
accept the risk of suspension, verification, or refusal of service;
bear responsibility for the use of funds with elevated AML risk.
10. Final Provisions
The Service reserves the right to amend this Policy. The updated version becomes effective upon publication on the website.
For AML/KYC/KYT and compliance inquiries: [email protected]
