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    AML / KYC / KYT Policy

    Last Updated: June 11, 2026

    Risk-Based, Not Routine KYC

    Bit2Pal operates as a limited-verification exchange. We do not require routine identity checks for ordinary low-risk use, but every order may be screened under our AML, KYC, and KYT controls, whether performed by Bit2Pal directly or by relevant payment and compliance partners.

    1. Purpose of This Policy

    Bit2Pal is committed to preventing fraud, money laundering, sanctions evasion, terrorist financing, stolen-funds movement, and other unlawful use of digital assets or payout channels.

    By using Bit2Pal, you confirm that the information you provide is accurate, that you are acting on your own behalf or with full authority, and that your funds do not originate from illegal or prohibited activity.

    2. How We Screen Transactions

    We and our payment, security, or compliance partners may use internal controls, sanctions screening, and blockchain analytics to review wallet addresses, transaction patterns, payout details, geolocation signals, and other risk indicators relevant to a specific order.

    • Every order may be screened before payout or refund.
    • Risk scores may change over time as new blockchain data appears.
    • We may apply enhanced review where an order shows elevated fraud, sanctions, source-of-funds, or payout-delivery risk.

    3. When Limited Verification May Be Required

    We or our payment or compliance partners may request limited KYC or additional source-of-funds information when reasonably necessary, including when:

    • The transaction is flagged by AML or KYT tools.
    • The source of funds cannot be verified with sufficient confidence.
    • We detect fraud indicators, impersonation, or third-party abuse.
    • A payment partner, liquidity partner, or competent authority asks for clarification.
    • The order involves a restricted jurisdiction or an unsupported cross-border payment corridor.

    4. What We May Request

    If enhanced review is required, we may ask for only the information reasonably needed for the case, such as:

    • Proof of identity.
    • Proof of address or country of residence.
    • Proof of wallet control or transaction ownership.
    • Explanation and evidence of the source of funds.
    • Clarification of the intended PayPal recipient or payout purpose.

    We reserve the right to decline incomplete, misleading, or falsified submissions.

    5. Prohibited Activity and Prohibited Sources

    Bit2Pal may refuse, pause, or reverse transactions linked to unlawful conduct or unacceptable source-of-funds risk.

    • Fraud, scams, chargeback abuse, or impersonation.
    • Darknet markets, ransomware, malware, or stolen funds.
    • Mixers, tumblers, obfuscation tools, or deliberate tracing evasion.
    • Sanctions evasion or dealings with sanctioned persons or entities.
    • Illegal goods or services, terrorist financing, human trafficking, or child exploitation.
    • Anonymous or unverified P2P brokers, unlicensed processors, or payout intermediaries we cannot validate.

    Examples of commonly blocked or escalated source types include Tornado Cash, Blender.io, ChipMixer, Sinbad or Shinbad, Hydra, Lazarus-linked infrastructure, sanctioned exchanges, and other high-risk services identified by our compliance tools. This list is illustrative, not exhaustive.

    6. Restricted Jurisdictions and Unsupported Corridors

    Bit2Pal does not serve users or transactions involving jurisdictions subject to applicable sanctions, jurisdictions where cryptocurrency exchange is unlawful, or locations where PayPal or other cross-border payment delivery cannot be completed reliably.

    • Orders may be declined if the destination country does not support the required international payout flow.
    • Orders may be declined if local banking, sanctions, or compliance controls make delivery impractical or unsafe.
    • Using VPNs, proxies, Tor, or similar tools to hide location or bypass regional restrictions is prohibited.

    7. Holds, Refusals, and Refunds

    If an order is flagged for compliance review, we may place the order on hold while we investigate. During this period, payout or refund may be delayed until our review or a partner review is complete.

    • We may request documents or supporting evidence before deciding whether to complete, reject, or refund the order.
    • We may refuse service where risk remains unacceptable or required verification is not provided.
    • If a refund is permitted, it may be returned minus applicable network, processing, and verified third-party costs.

    Compliance reviews typically take 1 to 10 business days, but complex cases may require more time, especially when third-party responses or additional evidence are needed.

    8. Data Use and Cooperation

    Information collected during compliance review may be retained and shared where required for fraud prevention, sanctions compliance, legal obligations, dispute handling, or legitimate requests from payment providers, banking partners, or competent authorities.

    To protect our controls, we may limit the detail we disclose about internal risk models, monitoring methods, or investigation outcomes.

    9. Compliance Contact

    Compliance-related communication is usually sent to the email address provided in the order, whether the review is handled by Bit2Pal or a relevant partner. You may also contact us via support@bit2pal.com for review updates or document submission instructions.

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