AML & KYC Policy

These AML & KYC Policy are applicable to the services that were provided until July 18, 2023. website is owned by Money Flow OÜ , a company registered under the number 14845103. Until July 18, 2023, Money Flow OÜ provided virtual currency services under licence number: FVT000047. After this date, Money Flow OÜ discontinued the provision of crypto exchange services at its own discretion and own decision, and the legal entity underwent a change in its area of economic activity. Money Flow OÜ has its registered and operational address at Valukoja tn 8/1, 11415, Estonia, located in Harju maakond, Tallinn, Lasnamäe linnaosa.

Having regard to the safety of the users and due to the legal requirements of the Government of Estonia, The European Union, The Unity States of America and other countries, Money Flow OU has implemented and started to use KYC policy (customer’s identification), AML / CTF (combating money laundering and terrorist financing) as it is required from banks and other financial institutions.

The purpose of those policies is an effective combating of money laundering and terrorist financing (AML / CTF) on our exchange by proper identification of actual users of our accounts and supervision of their transactions. We shall identify and cease transactions made not only to purchase/sell a cryptocurrency but made mainly to hide the criminal origin of money, finance illegal activity or other unlawful behaviours.

Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users. We would like to introduce to you some of the general rules and stipulations of our policies which directly concern you and affect the services we render.

User’s identification

In the first place, we are obliged to identify, beyond a reasonable doubt, the identity of persons enabled to do transactions on our exchange. This is the reason why we collect ID scans, which authenticity is verified with special software of professional external providers.

We require completing an automated identity check or ID document in order to preclude the possibility of using your documents by someone else. Verification of your likeness to the photo from your ID is made with the use of special software of professional external providers or, in case of doubts, done manually by our customer support services.

In case of any doubts, our customer support team will contact you to explain any concerns and solve the issues that arose.

If we cannot determine, beyond a reasonable doubt, that the documents you provided belong to you and are authentic we won’t be able to let you execute any transactions.

User’s identification – Companies

In the case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who is the owner of the company, who can represent it, where the company is based and what is the business of the company.

Since standards regarding governmental documentation of legal entities are different in each country, every time the verification of such users is done “manually” and is considerably more time-consuming.

Transactions’ monitoring and supervision

Using our proprietary software we also analyze all transactions that take place on our exchange looking for suspicious and unusual behaviour. Such selected transactions are analyzed by our AML specialists and evaluated if they do not provide significant AML / CTF risks or if they needed to be ceased and clarified with the User.

Additional verification

When your trade volume rises, our AML / CTF verification duties increase as well. The same happens when your transactions are “flagged” as suspicious or unusual, or our verification of your personal results in qualifying you as a person imposing significant AML / CTF risk.

In such cases, we can require additional documentation proving your real, exact place of residence, education, occupation, as well as the source of money you are using on the exchange.

Unfortunately, If our AML specialists decide information received from you doesn’t clarify our doubts, we will be obliged to end our cooperation with you or even report your transactions to relevant authorities.

In terms of the provision of the policy of the Anti-Money Laundering Act and our Terms of Service of the licensed financial institution, the update of the KYC documents for all accounts is carried out at periodic intervals. The customer account requires a KYC update once in 6 (six) months and you will be requested to submit the KYC documents in order to keep your account active. If KYC is not updated by submitting the documents, Money Flow OU ( may opt to freeze/close the account without further notice. In this case, when you decide to use our service again, you will have to register a new account and submit your full KYC documentation at that moment.

Basic AM / CTF Rules

Our operating rules include inter alia as follows:

  • Money Flow OU ( does not accept cash deposits or cash withdrawals in any cases.
  • Money Flow OU ( does not accept any third parties’ deposits on the user’s account, managing the account on behalf of somebody, joint or shared accounts, etc.
  • Money Flow OU ( provides its buy / sell service only to customers’ own personal wallet addresses.
  • Money Flow OU ( does not allow any exceptions in the field of documentation required from users.
  • Money Flow OU ( reserves the right to refuse to process the User’s transaction at any time, in case of suspicion of AML / CTF risk.
  • In accordance with the international law, we are not obliged (or even forbidden) to inform our clients, if we report their behaviours as suspicious to relevant authorities.

Sanctioned countries

In accordance with our policies, we do not open accounts when your trade volume rises, our AML / CTF verification duties increase as well. The same happens when your transactions are “flagged” as suspicious or unusual, or our verification of your personal results in qualifying you as a person imposing significant AML / CTF risk. and do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations, or countries which based on various criteria selected by our AML team (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission) impose high AML / CTF high risk.

Currently, these countries are:

Afghanistan, Albania, Algeria, Bahamas, Barbados, Belarus, Bosnia and Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cayman Islands, Central African Republic, China, Congo, Cuba, Democratic Republic of Congo, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guinea Bissau, Haiti, Iran, Iraq, Israel, Jamaica, Japan, Jordan, Kyrgyztan, Lebanon, Libya, Mali, Malta, Maynmar, Morocco, Mozambique, Niger, Nigeria, Nicaragua, Pakistan, Palestin Territory,  Panama, Philippines, Puerto Rico, Russia, Senegal, Serbia, Somalia, South Sudan, Sudan, Saudi Arabia, Syria, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, Uzbekistan, United States, Venezuela, Virgin Islands U.S., Yemen, Zimbabwe.

Tiers of KYC verification

When your trade volume rises AML / CTF risk increases as well. That is why we have to introduce proper safety and verification procedures. As a result, we introduced two Tier verification system, based on the general rule that the more money (or cryptocurrencies) you deposit or want to withdraw the more information about you and your funds we need to exclude AML / CTF risks (as we are required by law).

You should remember that this model is a result of the work and experience of our AML team and can be changed as the legal requirements of countries change as well as a result of gaining new knowledge and experience. In particular transition, limits may change due to periodical audits and verification of efficiency of our procedures. We will keep you updated if any changes would influence your situation.

Risk disclosure

You agree that you are free to choose whether or not to use the service provided to you by Bitnomics and that you do so at your sole option, discretion and risk. The exchange of digital currency is considered a risky transaction with highly speculative outcomes. Bitnomics does not guarantee any profit from any activity associated with its services.

  • You agree that you are free to choose whether or not to use the service provided to you by Bitnomics and that you do so at your sole option, discretion and risk. You confirm that you understand and agree that the risks associated with the Services are acceptable by you, taking into account your objectives and financial capabilities.
  • You acknowledge that purchasing or selling Cryptocurrency carry significant risk. Prices can fluctuate on any given day. Because of such fluctuations, Cryptocurrency may gain or lose value at any time. Cryptocurrency may be subject to large swings in value and may even become absolutely worthless. Cryptocurrency trading has special risks not generally shared with official currencies, goods or commodities in a market. Unlike most currencies, which are backed by governments or other legal entities, or commodities such as gold or silver, Cryptocurrency is a unique kind of currency, backed by technology and trust. There is no central bank that can take corrective measures to protect the value of Cryptocurrency in a crisis or issue more currency.
  • You should carefully consider if holding digital currency is suitable for you depending on your financial circumstances. Dealing and exchanging in cryptocurrencies involves significant risk. The value of virtual assets / currencies has high volatility (value can increase and decrease significantly in a very short period of time and at any given moment). Such price fluctuations bring uncertainty. The value of a virtual currency and collapse in demand may be influenced by many factors, including irrational (or rational) bubbles, loss of confidence in the currency, changes in software development, government decisions, creation of a competitive currency, technical problems, political or non-political statements, statements of influencers and news and hacker-attacks.
  • Your virtual assets may be lost by losing your password, private key or other security code. Virtual currencies have special risks that are not generally shared with the official currencies, because they are not issued by governments, or with commodities or goods that are tangible or registered in the official registry. Virtual currencies are intangible, decentralized, digital assets, backed by technology and trust. No central bank or other institution can take any measures to protect the value of virtual currency. Virtual currencies are autonomous and largely unregulated system of firms and individuals issuing currencies. The risk of loss in buying, selling or holding virtual assets / currencies can be substantial. You should therefore carefully consider whether exchanging virtual assets is suitable for you in light of your financial condition. Be careful to keep your private keys, passwords, security codes and words for yourself and change them on a regular basis. Bitnomics uses payment providers for transfers of fiat money for rendering exchange services and operating with the fiat money, whereas assisting banks do not, by any means, represent a medium of exchange, transfer, withdrawal, deposit or other transaction in connection to virtual currencies.
  • You acknowledge and agree that Bitnomics does not act as a financial advisor, does not provide investment advice services or guidance, and any communication between you and Bitnomics cannot be considered as an investment advice. Without prejudice to our foregoing obligations, in asking us to enter into any transaction, you represent that you have been solely responsible for making your own independent appraisal and investigations into the risks of the transaction. You represent that you have sufficient knowledge, market sophistication and experience to make your own evaluation of the merits and risks of any transaction and that you received professional advice thereon. We give you no warranty as to the suitability of the Services and assume no fiduciary duty in our relations with you. We may provide information on the price, range, volatility of digital currency and events that have affected the price of digital currency, but this is not considered investment advice and should not be construed as such. Any decision to purchase or sell digital currency is your exclusive decision at your own risk and Bitnomics will not be liable for any loss suffered.
  • To the full extent permitted by the applicable law, you hereby agree to indemnify Bitnomics and its partners against any action, liability, cost, claim, loss, damage, proceeding or expense suffered or incurred if direct or not directly arising from your use of our website, your use of the service or from your violation of our terms and conditions.
  • Bitnomics is not liable for any price fluctuations in Cryptocurrency. In the event of a market disruption, Bitnomics may, at its discretion and in addition to any other right and remedy, suspend the Services. Bitnomics will not be liable for any loss suffered by you resulting from such action. Following any such event, when Services resume, you acknowledge that prevailing market rates may differ significantly from the rates available prior to such event.
  • Internet transmission risks. Client acknowledges that there are risks associated with using the Software and Services including, but not limited to, the failure of hardware, software, and internet connections. Client acknowledges that the Company shall not be responsible for any communication failures, disruptions, errors, distortions or delays client may experience when using the Software and Services, howsoever caused.