AML/KYC Policy for Cryptocurrencies transactions


Account: means an account registered by the User on the Disc Soft FZE LLC website or other Internet services, owned and operated by Disc Soft FZE LLC.

Services: mean all and any service provided by Disc Soft FZE LLC.

Transaction: means (i) transfer of Cryptocurrencies or Fiat currencies by the User to his/her Account (“Deposit Transaction”); (ii) withdrawal of Cryptocurrencies or Fiat currencies from his/her Account (“Withdrawal Transaction”).

User: means a person or an entity, who uses the Services, agreed to the Terms of Use and is a holder of an Account.

Withdrawal: means a Transaction involving a transfer of Funds from the User’s Account to his/her bank account or to account opened in any other financial institution.

Where the context so admits words denoting the singular shall include the plural and vice versa.

Scope of the services

Depending on the User’s place of residence, the User may not be able to use the Services. It is the User’s responsibility to follow those rules and laws in his/her place of residence and/or place from which the User accesses the Services.


Disc Soft FZE LLC Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of being involved in any kind of illegal activity.

Both international and local regulations require Disc Soft FZE LLC to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/KYC Policy covers the following matters:

  1. Verification procedures.
  2. Compliance Officer.
  3. Prohibited countries.
  4. Monitoring Transactions.
  5. Risk Assessment.
  6. Obligations to the user of Disc Soft FZE LLC services.

1. Verification procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD and “Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Guidelines for Banks, Financial Institutions, Credit Unions and Money Transfer Services Providers” by Central Bank of UAE (the Guidelines), Disc Soft FZE LLC establishes its own verification procedures.

Identification and verification procedures (also known as 'Know Your Customer' or ' KYC') are required for all Transactions, which involve Fiat currency. On its sole discretion Disc Soft FZE LLC may apply mentioned KYC procedures to Users, who make Transactions exclusively in Cryptocurrency. If the User refuses to provide required documents and information, Disc Soft FZE LLC reserves the right to immediately terminate Services provision to the User.

Identity verification

According to the Section IV of the Guidelines, Disc Soft FZE LLC’s identity verification procedure requires the User to provide Disc Soft FZE LLC with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Disc Soft FZE LLC reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

Disc Soft FZE LLC 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 Disc Soft FZE LLC reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Disc Soft FZE LLC reserves the right to verify User’s identity in an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Disc Soft FZE LLC reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Disc Soft FZE LLC Privacy Policy and related regulations.

Once the User’s identity has been verified, Disc Soft FZE LLC is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

Card verification

The Users who are intended to use payment cards in connection with the Disc Soft FZE LLC Services have to use third-party credit card payment providers, offered by Disc Soft FZE LLC. In such case, according to paragraph 4.6.3 of the Guidelines, Disc Soft FZE LLC is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by Disc Soft FZE LLC, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Disc Soft FZE LLC anti-money laundering and counter-terrorist financing, including but not limited to:

  • Collecting Users’ identification information.
  • Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
  • Monitoring transactions and investigating any significant deviations from normal activity.
  • Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
  • Updating risk assessment regularly.
  • Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

3. Prohibited countries.

BY Republic of Belarus

CN China

CD Congo, the Democratic Republic of the

CG Congo

CU Cuba

ER Eritrea

IQ Iraq

IR Iran, Islamic Republic of

HK Hong Kong

KP Korea, Democratic People's Republic of

LR Liberia

LY Libyan Arab Jamahiriya

RU Russian Federation

SD Sudan

SL Sierra Leone

SO Somalia

SY Syrian Arab Republic

Ukraine: Crimea, Donetsk and Luhansk regions


YE Yemen

ZW Zimbabwe

4. Monitoring Transactions

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Disc Soft FZE LLC relies on data analysis as a risk-assessment and suspicion detection tool. Disc Soft FZE LLC performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

  1. Daily check of Users against recognized “black-lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
  2. Case and document management.

With regard to the AML/KYC Policy, Disc Soft FZE LLC will monitor all transactions and it reserves the right to:

  • ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
  • request the User to provide any additional information and documents in case of suspicious transactions;
  • suspend or terminate User’s Account when Disc Soft FZE LLC has reasonable suspicion that such User engaged in illegal activity.

The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

5. Risk Assessment

Disc Soft FZE LLC, in line with the international and local requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Disc Soft FZE LLC is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

6. Obligations to the user of Disc Soft FZE LLC services

By using Disc Soft FZE LLC services, I confirm that me or close family members* or close associates** are not politically exposed natural persons. Otherwise I will inform Disc Soft FZE LLC about this situation by written notice to e-mail

*Close family members mean the spouse, the person with whom partnership has been registered (hereinafter referred to as cohabitant), the parents, brothers, sisters, grandparents, grandchildren, children and children's spouses, children's cohabitants.

**Close associate means a natural person who, together with the person who is or has been participating in the same legal person or maintains other business relations.

By using Disc Soft FZE LLC services I hereby confirm that I am the actual owner (beneficiary) of funds.

By using Disc Soft FZE LLC services I hereby confirm that I undertake all operations on my behalf and I am not authorized by any other person to undertake operations on his/her/its behalf. Otherwise I will inform Disc Soft FZE LLC about this situation by written notice to e-mail