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CryptoInvest (Edik-Norik LLC)
Last updated: July 11, 2026

Anti-Money Laundering and Know Your Customer Policy (AML/KYC)

Policy on Combating Money Laundering, Financing of Terrorism, and Customer Identification Procedures

1. General Provisions


This Policy has been developed for the purpose of preventing the use of the Company’s activities for money laundering and the financing of terrorism.


This Policy applies to all Users of the Service, regardless of their nationality, residency status, or transaction volume.


The Company operates in the field of crypto-asset exchange using external cryptocurrency wallets and cash funds. The Company does not store Users’ funds.

2. Risk-Based Approach


The Company applies a risk-based approach when assessing Users and their transactions. Risk assessment is carried out taking into account

  • the User’s country of residence or registration;
  • the nature and volume of transactions;
  • the use of cash funds;
  • ownership structure (for legal entities);
  • other factors that may affect the level of risk.


Depending on the level of risk, the Company reserves the right to apply additional verification measures or to refuse the User’s request (reference to Clause 10.4 of the Terms of Service).


3. Identification and Verification (KYC)


3.1. Mandatory Nature of Identification


The Company carries out full identification and verification of each User’s identity prior to granting the ability to submit requests for transactions involving crypto-assets and/or cash funds through the Service. Simplified identification procedures are not applied.


3.2. Procedure for Verification


Verification is conducted through an automated identification system using specialized software. The procedure includes:

  • uploading an identity document;
  • automated verification of document authenticity;
  • biometric identification;
  • screening against sanctions and other relevant lists;
  • assessment of the User’s risk level.


The Company is entitled to engage third parties to perform identification and verification procedures.


Responsibility for compliance with the legislation of the Republic of Armenia lies entirely with the Company.

4. Identification of Natural Persons


4.1. Prior to submitting a request for the exchange of crypto-assets or fiat funds, each User is required to register a personal account on the Service’s website and complete the mandatory verification procedure through AMLbot KYC. Without passing verification, submission of requests is not possible.


4.2. Identification is carried out on the basis of reliable and valid documents and information, including:


  • full name;
  • citizenship;
  • registered address and/or actual place of residence;
  • date of birth;
  • document type, number, and date of issue of the identity document.


4.3. The Company maintains records of all material terms of transactions concluded with or on behalf of the User, including:


  • date and time of the transaction;
  • type of transaction (purchase, sale, exchange, etc.);
  • amount and currency;
  • crypto-assets involved in the transaction, including quantity and price;
  • method of execution (cash / non-cash);
  • transaction counterparties’ details;
  • other transaction parameters required to comply with the legislation of the Republic of Armenia.


4.4. All information is stored in accordance with the legislation of the Republic of Armenia and the Company’s internal procedures for a period of not less than five (5) years.


5. Identification of Legal Entities


When establishing business relations with a legal entity, the Company carries out:


1. Identification of the legal entity:

  • full legal name;
  • legal form;
  • registration data;
  • taxpayer identification number (TIN);
  • registered legal address.

2. Identification of the legal representative and verification of their authority.

3. Identification and verification of ultimate beneficial owners (UBO).

4. Analysis of ownership structure and nature of business activities.

The Company reserves the right to request incorporation documents, registry extracts, and other information necessary for risk assessment.

6. Politically Exposed Persons (PEP)


A PEP is a natural person who holds or has held a prominent public, political, or governmental position, as well as their family members and persons having close business or personal ties with them.


6.1. Restrictions on PEP Services

The Company reserves the right to refuse to process a User’s request upon identification of PEP status, and to suspend transactions if such status is identified during the course of service provision.


7. Enhanced Due Diligence (EDD)


In cases of elevated risk, the Company applies enhanced due diligence measures, including:

  • requesting confirmation of the source of funds;
  • requesting confirmation of the source of wealth;
  • additional transaction analysis;
  • in-depth blockchain address analysis;
  • imposition of restrictions or limits;
  • refusal to execute the transaction.


8. Transaction Monitoring


The Company conducts ongoing monitoring of User transactions to identify suspicious, unusual, or potentially illegal activities, including:

  • analysis of transaction patterns and volumes;
  • comparison of transactions against the User’s profile;
  • screening of crypto addresses using AML analytics tools;
  • screening against sanctions and other restrictive lists.

9. Suspension and Blocking of Transactions


9.1. The Company has the right to suspend a transaction or temporarily restrict the User’s access to the Service functionality in the following cases

  • failure to provide requested documents;
  • detection of suspicious activity;
  • inconsistency between the transaction and the User’s profile;
  • necessity to conduct additional verification (EDD);
  • requirements of the legislation of the Republic of Armenia.


9.2. During the verification process, the Company is entitled to:

  • request additional documents;
  • request confirmation of the source of funds;
  • conduct in-depth blockchain address analysis;
  • refuse to process the request.


9.3. Transaction processing shall only be carried out after final confirmation of the status of received funds and the absence of restrictions imposed by third-party services, liquidity providers, or payment systems.


10. Refusal of Service and Termination of Business Relationship


The Company reserves the right to refuse to establish or continue a business relationship with the User in the following cases.

  • failure to pass the KYC procedure;
  • provision of false or misleading information;
  • identification of PEP status;
  • identification of links to sanctioned persons;
  • inability to determine the risk level;
  • identification of participation in high-risk activities.\

11. Restrictions on Sources of Funds and Prohibited Categories

The Company does not process transactions related to.

  • sanctioned jurisdictions;
  • platforms subject to international sanctions;
  • terrorism and extremism;
  • darknet, ransomware, or malware activities;
  • child exploitation;
  • stolen funds;
  • scams or fraud;
  • mixing services;
  • illegal gambling activities.


The Company reserves the right to refuse the User’s request for transactions classified as high-risk (User Agreement Clause 10.4).


12. Requirements for Crypto Deposits


Each crypto deposit must be sent to a unique address provided by the Company for a specific transaction. The use of a single address for multiple independent transactions without prior approval is prohibited. Violation of this rule may result in delays in processing funds until completion of the required verification procedures.

13. Specific Features of Conducting Transactions and Verification of Fund Recipients

13.1. For Individuals

The Company conducts transactions exclusively with Users who have successfully completed the identification and verification (KYC) procedure.

When conducting transactions, the User’s information must correspond to:

  • the owner of the payment instrument used to deposit or receive funds in non-cash transactions;
  • the individual who actually deposits or receives cash funds in cash transactions;
  • the owner of the payment details to which the funds are transferred.

The use of payment instruments, bank accounts, payment details, or cash funds belonging to third parties is prohibited.

Cash funds may be received exclusively by the User who has successfully completed the identification and verification (KYC) procedure.

If any discrepancy is identified or if third-party payment details are used, the Company shall refuse to process the transaction.

13.2. For Legal Entities

The Company conducts transactions on behalf of a legal entity exclusively through an authorized representative of that legal entity who has successfully completed the identification and verification (KYC) procedure.

Before conducting a transaction, the Company verifies the representative’s authority to act on behalf of the legal entity. For this purpose, the Company may request documents confirming such authority, including, but not limited to:

  • documents confirming the appointment of the head of the legal entity;
  • a power of attorney or other document confirming the representative’s authority;
  • incorporation documents or information obtained from official state registers;
  • any other documents necessary to confirm the representative’s authority.

When purchasing crypto-assets, the Company accepts funds exclusively from the legal entity represented by the authorized representative who has successfully completed the identification and verification (KYC) procedure.

When selling crypto-assets, the Company transfers funds exclusively to the bank account of the legal entity represented by the authorized representative who has successfully completed the identification and verification (KYC) procedure.

The use of bank accounts, payment instruments, or payment details belonging to third parties is prohibited.

The Company reserves the right to refuse to conduct a transaction if it is unable to verify the authority of the legal entity’s representative or if an elevated AML/CFT or anti-fraud risk is identified.