AML & Compliance Policy

This AML & Compliance Policy describes how Explace.io monitors transactions and manages compliance-related risks associated with digital asset exchanges.

The purpose of this policy is to:

• prevent the use of the service for unlawful financial activity;
• comply with applicable AML and sanctions requirements;
• maintain stable relationships with liquidity providers and infrastructure partners;
• ensure fair and transparent treatment of legitimate users.

Explace.io applies a risk-based compliance approach and does not automatically restrict transactions solely due to indirect or historical wallet exposure without additional risk indicators.

Transactions processed through Explace.io may be reviewed using:

• blockchain analytics providers;
• internal transaction monitoring systems;
• sanctions screening tools;
• compliance controls applied by liquidity providers (“LPs”) and infrastructure partners.

A transaction may be subject to additional review where there are reasonable indicators of:

• sanctions exposure;
• theft or fraud-related activity;
• ransomware-related activity;
• darknet marketplace activity;
• terrorist financing;
• intentional obfuscation of transaction origin where prohibited by applicable regulations;
• other activity reasonably associated with financial crime.

Explace.io evaluates transactions individually and considers:

• severity of exposure;
• transaction context;
• direct vs indirect exposure;
• recency of exposure;
• behavioral indicators;
• information voluntarily provided by the user.

The presence of indirect, low-risk, or historical exposure alone does not automatically result in a transaction restriction.

Where a user contacts Explace.io Support before initiating a transaction and provides wallet addresses, transaction details, or source-of-funds information for review, and such transaction is explicitly approved by the Support or Compliance team through official communication channels, Explace.io will generally not apply additional AML-related restrictions to the reviewed transaction.

Official communication channels may include:

• website support chat;
• verified Telegram support accounts;
• official email communication;
• other communication methods officially published by Explace.io.

This provision applies only to:

• the specific assets reviewed;
• the specific wallet addresses disclosed during the review;
• the transaction scope approved by Explace.io.

Explace.io reserves the right to reassess a transaction where:

• material information was omitted or misrepresented;
• the actual transaction materially differs from the reviewed transaction;
• a legal obligation arises after approval;
• an LP or infrastructure partner imposes a restriction after approval.

Explace.io may temporarily suspend or refuse processing of a transaction where a compliance review is reasonably required.

Such review may include:

• additional blockchain analysis;
• verification of wallet ownership;
• source-of-funds clarification;
• review by an LP or infrastructure partner.

Where additional review is required, processing times may increase until the review is completed.

Explace.io does not permanently retain user funds solely due to elevated risk scoring without additional compliance justification.

Where a transaction cannot be processed due to compliance-related reasons, Explace.io considers the return of funds to the original sending address to be the preferred and priority resolution whenever such return is technically and legally possible.

Explace.io does not benefit financially from compliance-related transaction returns and does not retain user funds for commercial gain. Any return of assets is performed solely for compliance, legal, security, or technical reasons.

Returns may be performed provided that:

• the assets remain under the control of Explace.io or its infrastructure partners;
• the assets have not been frozen, restricted, or withheld by a liquidity provider, custodian, or other third-party provider;
• the return does not violate applicable law, sanctions obligations, or compliance requirements.

Applicable blockchain network fees, third-party processing costs, and irreversible transaction expenses may be deducted from the returned amount where necessary.

Returns may not be possible in circumstances including, but not limited to:

• the transaction had already been executed through a liquidity provider or blockchain settlement process before the compliance review was completed;
• irreversible blockchain processing;
• restrictions imposed by a liquidity provider or infrastructure partner;
• legal or regulatory requirements;
• active law enforcement requests;
• security or fraud prevention obligations.

Explace.io operates using third-party liquidity providers and infrastructure partners which maintain independent compliance procedures and risk controls.

Where an LP or infrastructure provider freezes, restricts, or refuses to process funds associated with a transaction, Explace.io may be technically unable to complete the exchange or return the assets until such restriction is resolved.

In such cases, Explace.io may provide the user with reasonable evidence of the restriction, including:

• compliance notifications;
• transaction rejection notices;
• risk review confirmations;
• or other communications received from the relevant provider,

to the extent disclosure is legally permitted and does not violate confidentiality obligations.

Explace.io does not control independent compliance decisions made by third-party providers.

In cases involving elevated compliance risk, Explace.io may request additional information reasonably necessary to complete a review, including:

• proof of source of funds;
• proof of wallet ownership;
• transaction purpose information;
• identity verification where legally required.

Failure to provide requested information within a reasonable timeframe may result in:

• transaction cancellation;
• inability to complete the exchange;
• return of funds where possible;
• or refusal of service.

The service may not be used for:

• laundering proceeds of crime;
• fraud or theft-related activity;
• sanctions evasion;
• terrorist financing;
• ransomware-related transactions;
• unlawful financial schemes;
• knowingly processing stolen digital assets;
• any activity prohibited under applicable law.

Explace.io applies a presumption of legitimate use and good-faith conduct in relation to its users and their transactions unless there are reasonable and objective indicators suggesting otherwise.

The existence of indirect exposure, historical wallet association, elevated automated risk scoring, or isolated blockchain analytics indicators alone shall not automatically be treated as evidence of unlawful activity or malicious intent.

When conducting compliance reviews, Explace.io considers:

• the nature and severity of the identified risk;
• whether the exposure is direct or indirect;
• transaction context and behavioral factors;
• information voluntarily provided by the user;
• technical limitations and known inaccuracies of blockchain analytics systems.

Explace.io does not rely exclusively on automated AML scoring systems when making compliance decisions and seeks to apply proportionate, reasonable, and good-faith compliance measures.

The objective of Explace.io is to prevent unlawful use of the service while minimizing unnecessary restrictions, delays, or disruptions for legitimate users acting in good faith.

Explace.io has appointed a dedicated AML Compliance Officer to oversee the implementation, enforcement, and continuous monitoring of this AML & Compliance Policy.

The AML Compliance Officer is specifically responsible for:

• ensuring that Explace.io consistently applies a proportionate and risk-based compliance approach;
• overseeing transaction monitoring systems, escalations, and complex compliance reviews;
• acting as the primary point of contact for regulatory inquiries, law enforcement requests, and compliance audits;
• ensuring that the Compliance team makes fair, objective decisions in accordance with the principles of this Policy.

Any highly complex cases or disputes related to transaction restrictions are escalated to and overseen by the AML Compliance Officer. You may contact the AML Compliance Officer directly regarding such matters at [email protected].

Explace.io may update this AML & Compliance Policy periodically to reflect:

• legal or regulatory developments;
• infrastructure partner requirements;
• operational or risk-management changes.

The latest version published on the website shall apply to all future transactions.

Compliance-related inquiries, escalations for the AML Compliance Officer, and pre-transaction reviews may be submitted to our official email addresses: [email protected] or [email protected].