AML without KYC: we look at money, not people

Exchanging a deposit with a “dirty” history costs us more than usual: such funds can’t take the standard route, they need a separate path with extra steps and more expensive channels. At the base fee that deal loses money.

So every incoming transfer gets a risk score, and the price depends on it. Low risk — normal rate. High risk — a rate with a surcharge that covers those costs, or a refund if the surcharge doesn’t suit you.

The check also keeps the service from becoming a channel for money tied to crime: laundering proceeds, terrorist financing, drugs and weapons, human trafficking, corruption, hacks and fraud.

Exchanges go through without an account and without identifying you. We will never ask for:

• a passport, ID or licence
• a selfie with a document
• proof of address
• bank statements, contracts or certificates

What’s already in the order is enough: addresses, deposit and payout amounts, and the check result. We don’t sell this data or pass it to third parties.

The check is automatic and mandatory for every transfer — no exceptions. Specialised blockchain analytics services (KYT) look at the address the money came from and the path that money took before it.

The result is a score from 0 to 100. We calculate it ourselves from the address’s connections: what share of the funds is linked to which category, directly or through intermediaries, incoming or outgoing. Categories fall into classes:

• Critical — sanctions, terrorist financing, CSAM. They weigh the most.
• Severe — thefts and hacks, scams and phishing, darknet markets, ransomware, laundering. They raise the score sharply.
• Mixers — raise the score noticeably.
• Elevated — gambling, exchanges without customer checks, high-risk jurisdictions. They raise it moderately: money from such an exchange is usually ordinary.
• Neutral — exchanges, DEXs, bridges, DeFi, payment services and wallets. They don’t affect the score: every exchanger’s money goes through them, our own payouts included.

Distant links (through several intermediate addresses) weigh less than direct ones, and outgoing links weigh less than incoming. The score is proportional to the share: if only a small percentage of the funds is linked to a risky category and the rest is an ordinary exchange, the score stays low. Neutral categories don’t move it at all.

Categories come from analytics services and public databases, so their composition may change without separate notice.

A high score is not a block. We freeze nothing and demand nothing: the automatic exchange simply pauses, and a choice appears on the order page.

1. I

   Continue with a surcharge

   The deal completes as usual, only the payout is reduced by the surcharge. It grows with the risk: 0.8% at the 40-point threshold, rising evenly to 4% at 100. The exact figure is shown by the button.

2. II

   Get the deposit back

   The coins go to the address you give — we deduct only the network fee and, if needed, a commission.

No exceptions: every risky deposit is handled this way, links to sanctions included. We don’t hold your funds — nobody touches the coins until you decide, and the decision is always yours.

• Coins can be returned in two cases: you chose it on high risk, or the exchange is impossible — say, less than the minimum arrived.
• By default the funds go back where they came from; another address can be specified separately.
• The network fee for sending is deducted; sometimes our commission is added to it.
• You’ll see how much comes back before you press confirm; the final calculation happens at sending.

On some networks and tokens the network fee for a refund can be noticeable — you’ll see it in advance, in the final amount.

• You bring only money of lawful origin.
• You enter the payout and refund addresses — and typos in them are on you too.
• By pressing “Start exchange” you accept the coin check and everything described on this page.
• This policy is part of the 666.exchange rules. We may update it; the current version is always published on this page.