Русский1. General provisions
Exwell provides services via the exwell.io platform, including crypto-to-crypto exchange, acceptance of incoming transfers to a prepayment payment address, and payment for and performance of TRON network energy rental (including to third-party addresses and orders placed by a Partner via the Business API), while adhering to the principles of privacy, transparency, and user autonomy. The service seeks to provide a secure environment for operations and, at the same time, to comply with international standards on anti-money laundering, counter-terrorist financing, and sanctions restrictions. This policy applies to all such operations through Exwell.
2. Operating model and privacy
Exwell is focused on minimising the collection of users’ personal data. Under standard conditions, operations may be carried out without undergoing identity verification (KYC). At the same time, the service applies internal compliance controls that allow it to meet regulatory requirements without excessive interference with user privacy.
3. AML transaction monitoring
All transactions passing through Exwell are automatically analysed using third-party blockchain analytics tools, including, among others, AMLBot, Crystal, Elliptic, or other equivalent services at Exwell’s choice. Such screening assesses the origin of funds, transaction history, and matches against international databases and risk categories. Each transaction is assigned a Risk Score used as part of a risk-based approach.
For cryptocurrency exchange, the procedure described below applies, with a Risk Score threshold of 30%. Incoming prepayment is subject to AML screening of the transfer; crediting to the unused prepayment balance may be deferred or refused based on the screening result. A TRON energy rental order is not an exchange of the user’s funds; an order to a third-party address may be refused if the address is sanctioned or high-risk. For personal-account and Business API operations, Exwell may apply the same or additional checks.
4. Risk-based approach
The decision on how to process a transaction depends on the identified risk level. For cryptocurrency exchange: transactions with a Risk Score below 30% are processed in the ordinary course; transactions with a Risk Score of 30% or higher may be temporarily suspended for additional review, including KYC and/or Source of Funds confirmation. In addition to the numerical Risk Score, the service also takes into account extra risk labels, including indications of a link to stolen funds, fraud, ransomware, darknet resources, transaction-mixing services, sanctioned persons, and other elevated-risk sources.
5. Additional review
If a transaction is identified as potentially risky, Exwell may initiate an enhanced review. Such a review may include the following: manual analysis of the transaction by compliance specialists; a request for information on the origin of funds (Source of Funds); a request to undergo identity verification (KYC). Until the review is completed, the transaction and related funds may remain temporarily suspended. Incomplete crediting of prepayment and the unused prepayment balance may be suspended for the duration of the review in the same way as an exchange: this is a service under review or not yet provided, not a client wallet.
6. When KYC may be required
Exwell reserves the right to request a one-time KYC procedure in exceptional cases, including regulatory requirements, law-enforcement requests, court orders, sanctions checks, and other circumstances indicating a need for additional user identification. In such cases, the user may be directed to a vetted compliance partner to complete identity verification. The review period is typically up to 3 days. If the user refuses to undergo the requested review, the operation may be cancelled. For an exchange and for incoming prepayment not yet credited to the balance: funds may be returned to the sender less applicable network fees, if a return is technically possible. If prepayment has already been credited and no service has been ordered, the balance is unused prepayment; there is no withdrawal button. A return to the sender in that case is made only if Exwell itself cancels the credit (AML or a legal requirement).
7. Processing of personal data
Exwell seeks to minimise storage of KYC documents on its own servers. Identification procedures are generally performed by third-party compliance partners in accordance with applicable legal requirements, including the GDPR and other international data-protection standards. This does not mean that Exwell does not process other personal data of the user (account data, operations data, support enquiries) — such data are governed by the Privacy Policy.
8. Requested materials
As part of an additional review, the user may be required to provide documents and information necessary to complete the compliance procedure. For KYC, the following may be requested: a photo or scan of an identity document (passport, national identity card, or driving licence); a photograph of the user holding the identity document. To confirm the origin of funds (Source of Funds), the following may be requested: screenshots or statements from the wallet from which the transaction was sent; a history of operations confirming the origin of funds; screenshots of accounts at cryptocurrency exchanges or services through which the funds were received; an explanation of the source of funds. The service reserves the right to request additional materials if necessary to complete the review.
9. Review timeframes
After all required materials have been received, the review typically takes up to 3 business days. Until the required information has been received and the review completed, the transaction may remain temporarily suspended.
10. Conditions for returning funds
Following the review, the following outcomes are possible: completion of the exchange operation if no violations are identified; return of funds to the sender in respect of an exchange if the operation cannot be performed or the user refuses to undergo the review; return of funds to the sender in respect of incoming prepayment not yet credited to the balance, if crediting is refused or not possible; if prepayment has already been credited and no service has been ordered — unused prepayment; a return to the sender only if Exwell cancels the credit (AML or law), not as a withdrawal from the account; if an energy rental order has already been placed or performed — no return of prepayment: the service has been paid for; return of funds to the lawful owner if the service receives an official request or a binding order from competent law-enforcement authorities confirming the unlawful origin of the funds. Where a return is made, funds are sent to the relevant address in accordance with the review results and applicable legal requirements. If a return is made to the sender, funds are transferred to the original sender address within 24 hours after completion of the review, and only the network fee required to execute the blockchain transaction may be deducted. In this policy, “funds” / “stablecoin” means the assets of the operation without reference to a specific ticker.
11. Holding period
The period for which funds are held depends on the nature of the review and the circumstances of the particular case. In a standard review, funds may be held until the user has provided all required information and the review has been completed. In certain cases the holding period may be extended if required to comply with law or to fulfil official law-enforcement requests.
12. Restrictions on use of the service
Exwell does not support or permit use of the service for money laundering, terrorist financing, or other unlawful activity. The service does not cooperate with persons or organisations involved in fraud, sanctions breaches, or other unlawful acts. Users’ funds in respect of an exchange are not frozen except as expressly provided by law, court decisions, or binding regulatory requirements, and for the duration of the review described in this policy. Incomplete crediting of prepayment and the unused prepayment balance may be suspended for the duration of a review on the same grounds.
13. Energy rental to a third-party address
The user may specify any valid TRON network address as the energy rental recipient. Exwell may refuse an order if the address is sanctioned or high-risk. An energy rental order does not make Exwell responsible for subsequent transfers from that address.
14. For victims of theft
If you have been a victim of cryptocurrency theft and believe that the relevant funds may have been transferred through Exwell (including credited as prepayment), you must contact support at support@exwell.io (and/or via the form on the website) and provide a detailed description of the situation and available on-chain evidence. Documents from law-enforcement authorities relating to the relevant case may also be requested. Upon receiving an official legal request, Exwell may assist in tracing the transaction within the limits of its authority and applicable law. If the funds have already been exchanged, the service’s actions may be limited to the destination currency and may be taken solely on the basis of an official legal request. If the funds were credited as prepayment: the balance may be blocked; a return is made pursuant to law or to the sender, not as a withdrawal from the account.
15. Final provisions
Exwell seeks to maintain a balance between users’ financial privacy and the performance of regulatory duties. Use of the service constitutes the user’s acceptance of this KYC/AML policy.