letsexchange CryptoLightHouse Ltd., a company
incorporated and acting under the laws of the Republic of Seychelles (hereinafter –
“letsexchange”, “Company”, "we", "our" or "us") is committed to ensuring a secure
and compliant website located at: and any other our
websites (the "Website") and/or services that are available or enabled via the
Website (the "Services") for its users. As part of our commitment to transparency
and user safety, we have implemented this Know Your Customer Policy (the "KYC
Policy" or "Policy"). This Policy governs the KYC verification of users ("you",
"your", "users" or "Customer") who engage with our Website to ensure compliance with
our internal guidelines and with any applicable legal or regulatory obligations.
PLEASE NOTE THAT THIS POLICY DO NOT GOVERN ANY INTERACTIONS YOU MAY HAVE
WITH OUR THIRD PARTY PARTNERS, EACH OF WHICH HAS ITS OWN TERMS. PLEASE READ THIS
POLICY CAREFULLY BEFORE USING THE SERVICE.
By accessing and using our
Services and the Website, you acknowledge and declare that you are not located in,
or are not a citizen or resident of United States of America, Countries of the
European Union, United Kingdom, Afghanistan, North Korea, Crimea and Sevastopol,
Democratic Republic of Congo, Eritrea, Libya, Somalia, South Sudan, Sudan, Yemen,
Iran, Iraq, Cuba, Syria, Mali, Central African Republic, Guinea-Bissau, Lebanon or
any other country subject to United Nations Security Council Sanctions List and its
equivalent (the "Prohibited Jurisdictions").
The Company may change this
KYC Policy at any time without any notice, effective upon its posting on the
Website. Your continued use of the Website and Services shall be considered your
acceptance to the revised KYC Policy. If you have concerns or questions about this
Policy, please contact us at.
KYC/AML Policy
Last updated: March 18, 2025
Introduction
1. Scope
This KYC Policy applies to all users who
register, access, or utilize the Services provided through the Website. By using the
Website, you agree to the Company's right to request, review and verify the personal
information and/or documents (the "KYC verification") you provide as outlined below
in this Policy.
2. Circumstances for Verification
The Company reserves the right to initiate
KYC verifications on users in the following situations:
(i) At the Company's discretion: in order to protect the integrity of the Website and/or to make sure that the users do not access the Services from the Prohibited Jurisdictions as stipulated in this Policy or by the terms of the Terms of Use, and/or to avoid violations of the Terms of Use by the users, the Company may at its sole discretion, at any time, conduct KYC verification of the users;
(ii) At the request of our third-party partners: as exchanges are performed exclusively by the third-party partners, the Company may require KYC verification from users in response to requests made by such third-party partners. The third-party partners may have their own compliance obligations and may require KYC verification before/within facilitating transactions or exchanges. You can find a list of providers and their policies here
(i) At the Company's discretion: in order to protect the integrity of the Website and/or to make sure that the users do not access the Services from the Prohibited Jurisdictions as stipulated in this Policy or by the terms of the Terms of Use, and/or to avoid violations of the Terms of Use by the users, the Company may at its sole discretion, at any time, conduct KYC verification of the users;
(ii) At the request of our third-party partners: as exchanges are performed exclusively by the third-party partners, the Company may require KYC verification from users in response to requests made by such third-party partners. The third-party partners may have their own compliance obligations and may require KYC verification before/within facilitating transactions or exchanges. You can find a list of providers and their policies here
3. Customer Verification and Due Diligence
3.1. Our Know Your Customer (the “KYC”)
procedures and our third-party partners are designed to verify customer identities
and assess potential risks associated with their activities. We will collect certain
customer identification information from each customer who passes KYC; utilize
risk-based measures to verify the identity of each customer who passes KYC; record
customer identification information and the verification methods and results;
provide adequate KYC notice to customers that we will seek identification
information from to verify their identities. Based on the risk, and to the extent
reasonable and practicable, we will proceed with the verification to the extent that
we have collected all information needed in order to know the true identity of our
customers by using risk-based procedures to verify and document the accuracy of the
information we get about our customers.
3.3. Enhanced Due Diligence (the “EDD”) is applied to high-risk customers, including Politically Exposed Persons (the “PEP”), which includes:
PEPs are tracked through:
3.4. Customer information is updated and re-verified on a regular basis to ensure ongoing compliance with the AML/CTF requirements.
3.1.1. Sum & Substance Ltd, being our third-party service
provider, which entirely complies with our Privacy Policy in respect to
processing the personal information of our customers will analyze the
information we obtain to determine:
3.1.2. We will verify the information within a reasonable time, depending on the nature of the account and risk level of transactions. Our third-party partners may refuse to complete a transaction before we have verified the information, or in some instances, when we need more time, we may, pend verification, restrict transactions and the associated account under suspicion. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we will, after internal consultation with the firm’s AML Compliance Officer, pass the data on to our third-party partners, who in turn freeze the funds and file a SAR in accordance with applicable laws and regulations of their jurisdictions.
3.2. We collect and verify customer information using reliable, independent
sources, including: - whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies);
- whether the documents provided by the customers are valid and do not appear in the Specially Designated Nationals, PEP lists, Blocked Persons List or any other lists of sanctioned individuals (OFAC, UN, HMT, EU) or adverse media etc.
3.1.2. We will verify the information within a reasonable time, depending on the nature of the account and risk level of transactions. Our third-party partners may refuse to complete a transaction before we have verified the information, or in some instances, when we need more time, we may, pend verification, restrict transactions and the associated account under suspicion. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we will, after internal consultation with the firm’s AML Compliance Officer, pass the data on to our third-party partners, who in turn freeze the funds and file a SAR in accordance with applicable laws and regulations of their jurisdictions.
- Government-issued identification documents;
- Proof of address (e.g., utility bills, bank statements);
- Source of funds documentation.
3.3. Enhanced Due Diligence (the “EDD”) is applied to high-risk customers, including Politically Exposed Persons (the “PEP”), which includes:
- Obtaining additional identification documents;
- Verifying source of wealth and source of funds through:
- Bank statements;
- Tax returns;
- Property ownership records;
- Business financial statements;
- Conducting adverse media searches;
- Obtaining senior management approval for the business relationship;
- Implementing enhanced ongoing monitoring, including:
- More frequent transaction reviews;
- Regular updates of customer information;
- Annual risk reassessment
PEPs are tracked through:
- Initial identification during onboarding using PEP databases and screening tools;
- Ongoing screening of the customer base against updated PEP lists;
- Monitoring of transactions and activities for patterns consistent with PEP status.
3.4. Customer information is updated and re-verified on a regular basis to ensure ongoing compliance with the AML/CTF requirements.
4. Information Required for KYC Verification
4.1. The Company's KYC verification
procedure requires the users to provide the Company with reliable, independent
source documents, data or information (e.g., national ID, international passport,
bank statement, utility bill, source of funds, etc.) or in case of legal entities
the data and corporate documents showing the ultimate beneficial owner of such legal
entity upon the Company's request. For the KYC purposes the Company reserves the
right to collect users' identification information.
4.2. The Company will take steps to confirm the authenticity of documents and information provided by the users. All legal methods for double-checking identification information will be used and the Company reserves the right to investigate certain Customers who have been determined to be risky or suspicious.
4.3. The Company reserves the right to verify users' identity on an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular Customer). In addition, we reserve the right to request up-to-date documents from the users, even though they have passed identity verification in the past.
4.4. Users' identification information will be collected, stored, shared and protected strictly in accordance with the Company's Privacy Policy and related regulations.
4.5. The Company may always contact you to clarify the information given or ask for additional information which is needed for the KYC verification, or to address the risks of the case.
4.6. The Company may refuse to provide the service to the users without receiving additional information from the users upon the respective request.
4.2. The Company will take steps to confirm the authenticity of documents and information provided by the users. All legal methods for double-checking identification information will be used and the Company reserves the right to investigate certain Customers who have been determined to be risky or suspicious.
4.3. The Company reserves the right to verify users' identity on an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular Customer). In addition, we reserve the right to request up-to-date documents from the users, even though they have passed identity verification in the past.
4.4. Users' identification information will be collected, stored, shared and protected strictly in accordance with the Company's Privacy Policy and related regulations.
4.5. The Company may always contact you to clarify the information given or ask for additional information which is needed for the KYC verification, or to address the risks of the case.
4.6. The Company may refuse to provide the service to the users without receiving additional information from the users upon the respective request.
5. Third Party Partners
5.1. Within the text of this Policy the
term "third-party partners" shall refer to the third party providers who will
process the cryptocurrency exchanges. You can find a list of providers and their
policies here
5.2. The Company is not directly engaged in the exchange of cryptocurrencies. All exchanges are conducted by third-party partners. The Company may be required to verify user information at the request of the third-party partners, and users agree that their personal information may be shared with these third-party partners solely for the purpose of facilitating transactions or ensuring compliance with the applicable laws and/or regulations.
5.3. Cooperation with third-party partners is subject to the terms and conditions of each third-party partner. To the extent all third-party partners have policies including the AML/KYC policies that differ from this Policy, you may be required to agree to their terms in order to access their website and/or services.
5.4. Our third-party partners use transaction verification and employ systems to monitor transactions for suspicious activities (Know-Your-Transaction), including:
5.5. Our third-party partners reserve the right, at their sole discretion, to suspend, terminate or freeze your exchange transactions for any period of time, in the event (list is not exhaustive):
5.2. The Company is not directly engaged in the exchange of cryptocurrencies. All exchanges are conducted by third-party partners. The Company may be required to verify user information at the request of the third-party partners, and users agree that their personal information may be shared with these third-party partners solely for the purpose of facilitating transactions or ensuring compliance with the applicable laws and/or regulations.
5.3. Cooperation with third-party partners is subject to the terms and conditions of each third-party partner. To the extent all third-party partners have policies including the AML/KYC policies that differ from this Policy, you may be required to agree to their terms in order to access their website and/or services.
5.4. Our third-party partners use transaction verification and employ systems to monitor transactions for suspicious activities (Know-Your-Transaction), including:
- Unusual transaction patterns;
- Deviations from expected customer behavior;
- Customers requesting an exchange of untraceable cryptocurrencies;
- An ongoing investigation in regards to customers;
- The trading activity appears to be from higher-risk countries;
- Virtual asset transfers above the threshold set by the FATF guidelines;
- PEPs.
5.5. Our third-party partners reserve the right, at their sole discretion, to suspend, terminate or freeze your exchange transactions for any period of time, in the event (list is not exhaustive):
- If the customer fails (didn't successfully pass)/refuses to pass verification KYC
- If the transaction fails verification KYT
- If our third-party partners deems the transactions suspicious, unauthorized or fraudulent, including without limitation in relation to money laundering, terrorist financing, fraud or other illegal activities;
- If our third-party partners become aware or they suspect that any digital assets or funds may be associated with criminal proceeds or otherwise do not lawfully belong to you;
- the customer fails to provide, upon request, such documentation as the third party whose services we use to provide you with the Services under this Agreement reasonably requires to perform its obligations under applicable anti-money laundering laws and regulations or otherwise to ensure verification of your identity and/or sources of funding;
- if the third party whose services we use to provide you with the Services under this Agreement cannot verify or authenticate any information provided by you;
- we have received a corresponding order from any government authorities.
6. Non-Compliance with KYC Requirements
6.1. You acknowledge and agree that the
failure or refusal to provide the necessary information for the KYC verification may
result in the suspension of the Services provision and your ability to access the
Services provided on the Website.
6.2. The Company reserves the right to restrict or deny access to the Services in any location where the KYC verification is incomplete or fails to meet the required standards.
6.2. The Company reserves the right to restrict or deny access to the Services in any location where the KYC verification is incomplete or fails to meet the required standards.
7. Compliance Oversight and Management
7.1. Our Compliance Officer is responsible
for overseeing the implementation and enforcement of this policy. Their duties
include:
7.2. The Compliance Officer is authorized to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.
7.3. If we become aware of a SUSPICIOUS TRANSACTION we will prepare SUSPICIOUS TRANSACTION REPORT (STR) and submit to the Financial Intelligence Unit within two business days of ascertaining the reasonable grounds, forming the suspicion or receiving the information.
- Supervising all aspects of AML/CTF activities;
- Collecting and verifying customer identification information;
- Establishing and updating internal policies and procedures;
- Implementing a robust records management system;
- Updating risk assessments regularly;
- Liaising with law enforcement and regulatory authorities.
7.2. The Compliance Officer is authorized to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.
7.3. If we become aware of a SUSPICIOUS TRANSACTION we will prepare SUSPICIOUS TRANSACTION REPORT (STR) and submit to the Financial Intelligence Unit within two business days of ascertaining the reasonable grounds, forming the suspicion or receiving the information.
8. Collaboration with Law Enforcement Agencies
8.1. Our third-party partners obtain and
hold required and accurate originator information and required beneficiary,
information on virtual asset transfers, and make it available to appropriate
authorities on official request
8.2. Our company is always ready to cooperate with duly authorized law enforcement agencies, which in turn act in the manner and basis regulated by their legislation. Our company also strictly adheres to the rules for the protection of privacy and user data.
8.3. Request requirements:
8.4. For a quick and efficient response, please provide relevant transaction IDs, wallet addresses and any other identifiers in text form or in a separate XLSX file or other text format for tabular data presentation to avoid copy-pasting errors.
8.5. The usual period for reviewing a request is 1-2 business days. For complex requests and large volumes of dates, the review period is 5-10 business days. These periods do not include requests for additional/clarifying information, such as confirmation of authority, clarification of wallet addresses, etc.
8.6. Our company and our third-party partners (who collect information about exchanges) are not responsible for technical errors or omissions. We are also not responsible for delays in data processing.
8.7. Since our company does not conduct the exchange, but only collects information about the details of the exchange, we do not guarantee the accuracy of the information provided.
8.8. The company reserves the right to determine the response to each request at its own discretion based on legal requirements, operational capabilities and resource availability.
8.2. Our company is always ready to cooperate with duly authorized law enforcement agencies, which in turn act in the manner and basis regulated by their legislation. Our company also strictly adheres to the rules for the protection of privacy and user data.
8.3. Request requirements:
- Full legal designation of the requesting authority
- Complete credentials of the authorized officer(s)
- Official contact information for verification purposes
- Detailed specification of the information being requested
- Comprehensive legal basis and jurisdiction under which the request is made
- All pertinent case identifiers and reference numbers
8.4. For a quick and efficient response, please provide relevant transaction IDs, wallet addresses and any other identifiers in text form or in a separate XLSX file or other text format for tabular data presentation to avoid copy-pasting errors.
8.5. The usual period for reviewing a request is 1-2 business days. For complex requests and large volumes of dates, the review period is 5-10 business days. These periods do not include requests for additional/clarifying information, such as confirmation of authority, clarification of wallet addresses, etc.
8.6. Our company and our third-party partners (who collect information about exchanges) are not responsible for technical errors or omissions. We are also not responsible for delays in data processing.
8.7. Since our company does not conduct the exchange, but only collects information about the details of the exchange, we do not guarantee the accuracy of the information provided.
8.8. The company reserves the right to determine the response to each request at its own discretion based on legal requirements, operational capabilities and resource availability.
9. Data Protection
The Company is committed to maintaining
the confidentiality and security of all personal information collected for KYC
purposes. The Company will take all reasonable steps to protect users' data in
accordance with the Company's Privacy Policy and any applicable data protection
laws.
10. Contact us
- By email;
- In writing: Suite 1, Second Floor, Sound & Vision House, Francis Rachel str., Victoria, Mahe, Seychelles