Grizzly Exchange is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes. This AML Policy describes the procedures we use to detect, prevent, and report suspicious activity, ensuring compliance with international AML standards and applicable laws.

Money laundering is the process of disguising funds obtained from illegal activities as legitimate assets, concealing their true origin, ownership, or purpose.

Grizzly Exchange does not accept funds from or permit operations involving:

• Sanctioned countries and jurisdictions (including but not limited to: Russia, Belarus, Iran, North Korea, and others under international sanctions).
• Prohibited or high-risk platforms, such as: Bitpapa, Rapira, Grinex, Meer, Nobitex, 1xBet, Aifory, Terminal.cash, SkyCrypto, FlashObmen, 60cek, HD-Change, CoinBlinker, Metka, AlfaBit, Garantex, Hydra, Capitalist, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad, Bitzlato, Netex24, BTC-e, and similar platforms associated with criminal activity or high sanctions risk.

Any deposits or withdrawals connected to such sources will be blocked and may be reported to the relevant authorities.

To reduce the risk of money laundering and terrorist financing, each client must use their own verified account. Third-party deposits or withdrawals are not permitted.

Grizzly Exchange may requesst:

• Government-issued ID (passport, national ID, or driver’s license)
• Proof of residential address (utility bill or bank statement, not older than 3 months)
• Additional documentation such as source of funds evidence, transaction records, or communications confirming the legitimacy of funds

Accounts and transactions may be suspended if the requested documentation is not provided.

Additional checks are applied to high-risk clients or situations, including:

• Politically exposed persons (PEPs)
• Large or frequent transactions
• Customers from high-risk jurisdictions

EDD may require more in-depth verification and supporting documents.

All transactions are continuously monitored with a risk-based scoring system. Red flags include:

• Unusually large or rapid transfers
• Transactions inconsistent with normal customer activity
• Involvement of sanctioned jurisdictions, wallets, or entities

Suspicious transactions may be blocked, reported, or subject to additional verification.

The Company reserves the right to suspend or withhold any transaction for additional verification even if its AML risk level was assessed as low, in order to comply with internal policies, regulatory requirements, or in case of unusual activity.

Transactions suspected of money laundering, terrorist financing, or related crimes will be reported to the relevant authorities within 48-72 hours.

Grizzly Exchange securely stores AML records (KYC documents, transaction logs, risk assessments, and correspondence) for at least five (5) years from the first deposit. Records are made available to regulators or law enforcement upon request.

All customers and transactions are screened against major sanctions lists (OFAC, EU, UN, etc.). Transactions involving sanctioned individuals, entities, or addresses are blocked and reported.

Sanctions lists are reviewed and updated at least once per month to ensure ongoing compliance with the latest international requirements.

Transactions involving privacy-focused cryptocurrencies (such as Monero, ZCash, Dash, and MimbleWimble Coin) are classified as high-risk and require full KYC verification.

Exchanges involving cash are also high-risk and require enhanced checks.

Grizzly Exchange conducts all official communication through designated contact addresses. Authorized emails include: support@grizzly.exchange, compliance@grizzly.exchange.

We do not use free email services (such as Gmail, Yahoo, or ProtonMail) for official correspondence. Clients and partners should always ensure that communication comes from these official contacts.

A dedicated AML Compliance Officer is appointed to oversee AML efforts. Key responsibilities include collecting and verifying client documentation, overseeing AML procedures and updates, monitoring transactions and escalation of suspicious cases, and liaising with regulators and law enforcement.

• Collect and verify client documentation
• Oversee AML procedures and updates
• Monitor transactions and escalate suspicious cases
• Liaise with regulators and law enforcement

All staff undergo regular AML training to identify and escalate suspicious activity. Training programs are updated to reflect emerging risks and regulatory changes.

Grizzly Exchange cooperates fully with law enforcement and regulators. Required information is provided promptly (within 48-72 hours of a formal request).

This Policy is reviewed and updated regularly. Clients will be notified of significant changes via announcements on the Grizzly Exchange website or direct communication.

A risk-based approach is applied to allocate resources efficiently and focus on higher-risk activities. Assets frozen by regulatory order or law enforcement cannot be released and may be considered legal evidence.