AML/KYC Policy

Last updated: April 2026

1. Introduction

ChangeNOW is committed to preventing the use of its platform for money laundering, terrorist financing, and other illicit activities. This AML/KYC Policy outlines the procedures and controls we have implemented to detect, prevent, and report suspicious activity in compliance with applicable regulations.

2. Regulatory Framework

Our compliance program is designed in accordance with international anti-money laundering standards, including the recommendations of the Financial Action Task Force (FATF) and relevant jurisdictional requirements. We continuously monitor regulatory developments to ensure our policies remain current and effective.

3. Risk-Based Approach

ChangeNOW employs a risk-based approach to AML compliance, allocating resources proportionally to the level of risk associated with each transaction. Transactions are evaluated based on factors including volume, frequency, geographic origin, and blockchain analytics data to determine the appropriate level of due diligence.

4. When KYC Is Required

Most transactions on ChangeNOW are processed without identity verification. However, our automated AML monitoring system may flag certain transactions as high-risk based on predefined criteria such as unusually large amounts, connections to sanctioned addresses, or patterns consistent with illicit activity. When a transaction is flagged, the user will be required to complete identity verification before the exchange can proceed.

5. Verification Process

When KYC verification is triggered, users are asked to provide a government-issued photo identification document and, in some cases, a proof of address or a selfie for liveness confirmation. Our compliance team reviews all submitted documents promptly and communicates the outcome to the user as quickly as possible.

6. Record Keeping

ChangeNOW maintains records of all transactions and, where applicable, KYC documentation for the period required by applicable law. These records are stored securely and are accessible only to authorized compliance personnel and, upon lawful request, to competent regulatory or law enforcement authorities.

7. Suspicious Activity Reporting

When our monitoring systems or compliance team identify transactions that are suspected to involve money laundering, terrorist financing, or other criminal activity, we file Suspicious Activity Reports (SARs) with the relevant authorities. ChangeNOW employees are prohibited from disclosing to users or third parties that a SAR has been filed.

8. Sanctions Screening

All transactions are screened against applicable sanctions lists, including those maintained by the United Nations, the European Union, OFAC, and other relevant bodies. Transactions involving sanctioned individuals, entities, or jurisdictions are blocked and reported to the appropriate authorities.

9. Training

All ChangeNOW employees involved in compliance functions receive regular training on AML/KYC regulations, emerging typologies of financial crime, and the proper use of our monitoring and reporting tools. Training records are maintained and updated to reflect changes in regulatory requirements.

10. Policy Updates

This AML/KYC Policy is reviewed and updated periodically to reflect changes in regulatory requirements and industry best practices. Any significant updates will be published on this page with a revised effective date.

11. Contact

For questions regarding our AML/KYC procedures or to report suspicious activity, please contact our compliance team at compliance@changenow.io. We treat all compliance-related inquiries with the highest priority.