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

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

Grizzly Exchange explicitly prohibits accepting funds originating from sanctioned individuals, entities, or services, including but not limited to: Garantex, DuelBits, FreeBitcoin, Gandhiji.io, Hydra, NVSPC, Roobet, Tornado Cash, WEX Exchange, Yolo Group, Black Sprut, CommEx, BTC-e, Chipper Mixer, Stake, 1xBit, OMG!OMG!, DuckDice, Primedice, MEGA DARKNET MARKET, Wasabi Wallet, Bitzlato, Darknetone and DoubleWay exchanges.

Any funds received from these sources will be immediately blocked and reported to the relevant authorities.

The purpose of the range of anti-money laundering measures and procedures that Grizzly Exchange uses for accurate transactions is to ensure that customers using Grizzly Exchange services are equally identified by a single standard. This minimizes both their own risks and the risks of law-abiding clients being imprisoned in the illegal actions of third parties. To minimize the risks associated with money laundering and terrorist financing, we strictly do not accept or send payments to third (i.e. not identified) parties. Each client, to which their own account is assigned, has the right to send or receive payments using only their own accounts, whether they are accounts in electronic payment systems, bank accounts, credit / debit cards. We reserve the right to request verification and identification documents from users if suspicious activities are detected.

If Grizzly Exchange identifies unusual or suspicious transaction patterns, the customer may be asked to provide:

• A government-issued photo ID (passport, national ID, or driver’s license)
• Proof of residential address (utility bill or bank statement dated within the past 3 months)

We also reserve the right to request additional documentation, including but not limited to:

• Details about the origin of funds (source platform, transaction IDs, blockchain explorer links)
• Screenshots or records demonstrating legitimate acquisition of funds
• Relevant communication records confirming the transaction

Grizzly Exchange may refuse to process transactions or suspend accounts if requested documentation is not provided.

For high-risk transactions or customers, such as those involving politically exposed persons (PEPs), high-volume traders, or customers from jurisdictions identified as high-risk, Grizzly Exchange applies enhanced due diligence measures. This process may require additional verification steps and detailed documentation to ensure compliance.

Grizzly Exchange continuously monitors all user transactions and applies a risk-based scoring model. Transactions are flagged for review if they exhibit any of the following indicators, but not limited to:

• Significant deviation from normal user behavior
• Unusually large or rapid successive transfers
• Involvement of sanctioned regions or entities

We classify transactions as “high-risk” when the risk score is ≥ 60%, or as “medium-risk” if any of the category flags (e.g. Child Exploitation, Dark Market, Darknet Marketplace, Dark Service, Enforcement Action, Fraud Shop, Fraudulent Exchange, High-Risk Jurisdiction, Illegal Service, Illicit Actor/Organization, Mixer, Mixin, Ransom, Sanction, Scam, Stolen Coins, Terrorism Financing) exceed 10%.

When a transaction is flagged:

• 1. We report it to the relevant law enforcement or regulatory authority.
• 2. We may request additional information and documentation from the user.
• 3. We may block or suspend the transaction and, if necessary, the user’s account.

If a transaction clears enhanced due diligence, any refund issued will be net of a 5% commission fee.

For transactions with “high-risk” indicators (≥ 60% risk score or matching high-risk categories), Grizzly Exchange reserves the right to levy an additional fee of up to 15% to cover enhanced analysis and risk-mitigation costs.

As part of our crypto-processing workflow, we may hold a verified transaction’s balance either at its original on-chain address or in our secured cold wallet.

Any transaction reasonably suspected of money laundering, terrorist financing, or related crimes will be reported within 24 hours to the appropriate authorities. Affected customers will be notified in line with regulatory requirements.

We securely store AML records—including KYC documents, transaction logs, risk assessments, and correspondence—for at least five (5) years. Records are provided to regulators or law enforcement upon official request.

All customers and transactions are screened against major sanctions lists (e.g., OFAC, EU, UN). Transactions involving sanctioned parties are blocked and reported without delay.

Grizzly Exchange appoints a dedicated AML Compliance Officer responsible for:

• Collecting and verifying user identification information
• Drafting, reviewing, and maintaining all AML procedures and report templates required by law
• Monitoring transaction flows and analyzing deviations from normal activity
• Implementing a records-management system for secure storage and retrieval of AML documentation

The Officer also has the authority to liaise directly with law enforcement, financial intelligence units, and other regulatory bodies in matters of preventing money laundering, terrorist financing, and related financial crimes.

All Grizzly Exchange personnel receive ongoing AML training to recognize and escalate suspicious activity. Training materials and sessions are updated regularly to reflect regulatory changes and emerging threats.

Grizzly Exchange fully cooperates with domestic and international law enforcement, regulatory agencies, and financial intelligence units. We provide requested information in a timely manner under applicable legal frameworks.

This AML Policy is regularly reviewed and updated to reflect changes in regulatory requirements and global AML standards. Users will be notified of significant changes via announcements on the Grizzly Exchange website and by direct email notification.

Following international standards, Grizzly Exchange applies a risk-based approach to combat money laundering and terrorist financing. Measures implemented to prevent such activities are proportionate to the identified risks, enabling efficient allocation of resources by prioritizing higher-risk situations.

Assets that have been subject to a request from competent authorities or seized/frozen by other jurisdictional entities cannot be returned. In such instances, the frozen assets may be considered material evidence.