General Provisions

1.1. TorsaEst Group OU (hereinafter the Company) must strictly adhere to the policies and procedures set forth in this document (hereinafter the Policy).

1.2. These rules of procedure for the prevention of money laundering and the financing of terrorism, as well as the observance of international sanctions (hereinafter referred to as the Rules) establish requirements for verifying clients and transactions in order to prevent the conclusion of transactions related to money laundering and the financing of terrorism, as well as to ensure identification and report on such activities.

1.3. The company develops this Policy, makes changes and additions to it at its discretion and monitors its compliance.

1.4. The Client is obliged to become familiar with the Policy prior to its adoption by the Privacy Policy. The acceptance by the Client of these Rules, as well as the fulfillment by the Client, who previously accepted the specified Rules, of transactions (operations) in means that the Client agrees with all the provisions of the current version of this policy.

1.5. This policy is an integral part of the Terms of Use. When a Client of the Company accepts the terms of the user agreement, they automatically agree with the AML and KYC policies.

1.6. We draw Client’s attention to the fact that our Services are not available in every country. In particular, the Company does not provide its Services:

  • - citizens or residents of countries that have been included in the FATF black list (Iran and Democratic People’s Republic of Korea);
  • - to citizens and / or residents of the United States of America, Japan, Canada, Cote d’Ivoire, Afghanistan, Iraq, Congo, Guyana, Laos, Liberia, Somalia, Sudan, Thailand, Vietnam, China, Bolivia, Colombia, Ecuador, Algeria, Bangladesh, Indonesia, Jordan, Kyrgyzstan, Morocco, Nepal, Saudi Arabia, Pakistan, Taiwan, Cambodia, Russian Federation.

2. AML and KYC procedures

2.1. In order to make a transaction, the Client shall undergo the process of verification.

2.2. Depending on the sum, the requirements for the verification might be different. Additional documents may also be required. In general, the Client should confirm the email address, submit photos of an id/passport or submit a selfie with an id/passport, a card, where are 4 first and 4 last digits (a Client should hide the rest) and the owner's first and last name and a document confirming the actual address of residence to

2.3. Requirements for photo / scan of the id/passport. The passport or ID card provided for verification must contain the following information:

1. Country that issued the document

2. The serial number of the document proving the identity

3. Date of issue

4. Gender

5. Surname

6. Name

7. Date of birth

8. Place of birth

9. Date of expiry

Requirements for photo / scan of the utility bill. It can be:

  • - Statement from the bank
  • - Utility bill
  • - Tax documents
  • - A document confirming residence and issued by local authorities
  • - Court documents
  • - Documents issued by government or other competent authorities.

Note: The document confirming the place of residence must be not older than 3 months and must contain a full name and home address

2.4. In order to exchange large amounts, Source of wealth is required.

Source of wealth is how the Client got the funds, for example from selling a property, an inheritance payment or a divorce settlement. Source of funds means the details of the bank account that the investment funds come from.

It may be:

  • 1. Savings from salary (basic and/or bonus) Original or certified copy of a payslip (or bonus payment) Letter from employer confirming salary Latest audited accounts (if self-employed) and company bank statement
  • 2. Sales of shares or other investments / liquidation of investment portfolio Certified investment/savings certificates, contract notes or cash-in statements Bank statement clearly showing receipt of funds and investment company name Signed letter detailing funds from a regulated accountant
  • 3. Sale of property Signed letter from solicitor Certified copy sale contract Signed letter from estate agent
  • 4. Inheritance Grant of probate (with a copy of the will), which must include the value of the estate Signed letter from solicitor
  • 5. Company sale Signed letter from solicitor or regulated accountant Copy of contract of sale, plus bank statement showing proceeds Copies of media coverage (if applicable) as supporting evidence
  • 6. Company profit Certified copy of latest audited company accounts
  • 7. Gift Donor’s source of wealth (requirements of evidence as stated above for each individual source of wealth and a letter from the donor confirming details of the gift)

2.5. The Client’s identity and the provided wallet are checked by the internal AML team and service providers against a number of sanction lists, PEP, other black lists and go through adverse information screening. Only after a successful verification the Client can proceed to making a transaction. Once verified, the Client enters the Company’s clients’ system and is subject to constant ongoing monitoring by the Company’s AML team and third party providers. The service provider must identify and verify the Client, being in the same place as the Client, or using information technology tools.

2.6. After successful verification of the AML/KYC procedure, the transaction will be executed.

2.7. If the User refuses to undergo the AML/KYC procedure, the transaction will be rejected and the cryptocurrency assets will be returned to where they came from, minus any applicable fees.

3. Detection of suspicious activity

3.1. Suspicious activity means any financial transaction of the Client that may be associated with money laundering activities.

3.2. The Company is required to continuously monitor and update the suspicious activity detection systems used by the Company's system.

3.3. The Company will constantly conduct inspections in relation to its Clients and carefully check the transactions that they carry out in order to make sure that these transactions are compatible with the Company's knowledge of Clients, their business and the source of funds.

3.4. The company will periodically process lists published by Estonian authorities and international organizations and containing a list of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, limited liability countries, jurisdictions that are not provided with a sufficient level of laundering procedures and sanctioned countries to determine whether the Client or potential Client is included in the above lists and lists countries and / or with countries of its jurisdiction.

3.5. The Company reserves the right to recognize that a particular transaction is suspicious, based on personal observations and experience of the Company's employees, as well as on the basis of information received or disclosed.

3.6. The Company in accordance with international requirements, applies risk assessment practices to combat money laundering and terrorist financing.

3.7. The company keeps records of suspicious transactions and regularly alerts law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities regarding such transactions.

User data is transmitted when:

  • - Required by law;
  • - Disclosure is necessary to investigate violations of our Terms of Use or Privacy Policy;
  • - Disclosure is necessary to prevent damage or financial loss;
  • - Disclosure is necessary for reporting alleged illegal activity.

4. Confirmation of compliance

4.1. The Company's Client confirms that they have read and understood this Policy and that they (or the company) will operate in full compliance with the requirements and standards described in the Policy and will comply with all applicable laws and other regulations and requirements governing their activities as a Company’s Client.

4.2. The Client of the Company acknowledges that they are responsible for their actions in accordance with the current legislation in the field covered by this Policy, and is obliged to bear responsibility in connection with its failure.

5. Disclaimer

The Company has the right to make changes and additions to this AML/KYC policy, and undertakes to notify Clients via mail or on the official website of the company.

6. Contact

All questions regarding the AML/KYC procedure can be sent to