This Anti-Money Laundering and Counter-Terrorist Financing Policy (the “Policy” or “AML/CFT Policy”) of INit (“We”, “Us”, or “Company”) has been prepared in accordance with the applicable anti-money laundering and counter-terrorist financing legislation, including but not limited to the laws and regulations of the jurisdiction governing the Company entity providing the relevant service.
Money laundering and terrorist financing threaten the integrity and stability of the global financial system. As a responsible participant in the international community, we understand the crucial need to address these threats. Therefore, we are dedicated to establishing a robust Anti-Money Laundering (“AML”) and Combating Terrorism Financing (“CTF”) program that meets the highest legal and regulatory standards.
In addition to this public-facing Policy, we maintain a comprehensive internal AML/CFT Policy and related procedures, which set out detailed operational requirements for our employees and ensure consistent application of all legal, regulatory, and internal compliance obligations.
This Policy outlines the fundamental principles of our AML and CTF measures, which we strictly adhere to. All terms used in this Policy shall be interpreted in accordance with the applicable anti-money laundering and counter-terrorist financing legislation of the jurisdiction governing the relevant Company entity, as well as the Terms of Use of INit.
1. Purpose of this Policy
The purpose of this Policy is to ensure INit’s full compliance with applicable laws and regulations on the prevention of money laundering and terrorist financing in the jurisdiction of the Company entity providing the relevant service.
Through this Policy, we aim to:
- Protect the integrity and stability of the global financial system.
- Comply with all relevant legal, regulatory, and supervisory requirements.
- Prevent the misuse of our services for money laundering, terrorist financing, or other illicit activities.
- Promote a culture of compliance, transparency, and accountability in our business activities.
2. What are Money Laundering and Terrorist Financing?
Money laundering is the process of concealing the illegal origin of funds so that they appear to come from legitimate sources. It often involves placing illicit funds into the financial system, moving them through various transactions to obscure their origin, and reintroducing them as apparently lawful assets.
Terrorist financing is the collection or provision of funds intended to support terrorist acts, individuals, or organizations. These funds may come from both legal and illegal sources and are used for activities such as planning, training, and carrying out terrorist attacks.
Both money laundering and terrorist financing are serious crimes that threaten the stability of the global financial system. Preventing them is a legal requirement and a core part of our responsibility as a regulated service provider.
3. Who operates the INit platform?
Our services are provided through the website https://in1t.io, the Telegram bot https://t.me/in1tbot, and any other official channels we may introduce in the future.
The INit platform is operated by the relevant INit company entity, depending on your location and the service you use. Each entity is authorized to operate as a virtual currency exchange and custodian virtual currency wallet provider in accordance with the laws of its jurisdiction.
Details such as the legal name, registration number, and registered address of the operating entity will be provided in our official communications, on request, or as required by law.
4. Why do we need to verify your data?
We are legally required to identify and verify all our users before providing services. This process helps us:
- Comply with AML/CFT laws: We must follow anti-money laundering and counter-terrorist financing regulations in the jurisdiction of the INit entity providing your service.
- Follow regulator guidance: Our activities are supervised by competent authorities who require us to apply proper due diligence measures.
- Protect our platform: Verifying your identity helps prevent fraud, money laundering, terrorist financing, and other illegal activities.
We cannot provide our services without completing this verification process.
5. Can you use our services without passing KYC?
No. All users must complete the Know Your Customer (KYC) verification before using INit services.
If you do not provide the required information or documents or if they are incomplete, incorrect, or not up to date we will be unable to offer you our services.
In certain cases, and in line with legal requirements, we may apply a simplified onboarding process for users whose total deposits or withdrawals stay below EUR 699 (or equivalent in another currency). Whether this simplified process applies will depend on our internal risk assessment and is at our discretion.
We may update our KYC procedures at any time to reflect legal changes or improvements to our compliance processes.
6. What is Customer Due Diligence (CDD)?
Customer Due Diligence (CDD) is the process we use to confirm your identity and assess the risk of money laundering, terrorist financing, or other illegal activity connected to your account.
CDD helps us understand:
- Who you are — by verifying your identity and background.
- The nature of your activities — so we can assess the level of risk.
- How you use our services — so we can monitor for unusual or suspicious activity.
As part of CDD, we may:
- Verify your identity (for individuals and legal entities).
- Identify anyone acting on behalf of a legal entity.
- Verify shareholders and beneficial owners.
- Assess your risk profile.
- Monitor your activity while you use our services.
We may also ask for documents proving your address, source of funds, or source of wealth if needed to meet our regulatory obligations.
7. What information do we request from individual users?
As part of our customer due diligence process, all individual users must complete identity verification before accessing our services.
We may request the following information and documents:
- A valid government-issued identity document (passport, national ID card, or driver’s licence).
- A liveness or facial similarity check to confirm that the document belongs to you.
- Contact details, including email address, phone number, and residential address.
- Basic information on the purpose of your account and your source of funds.
- Any declarations required under applicable AML/CFT laws, such as confirmation that you are not a Politically Exposed Person.
Depending on your location, the nature of your activity, or the risk assessment outcome, we may request additional documents or information, such as proof of address, proof of funds, or source of wealth.
8. What information do we request from legal entities?
Before providing services to a legal entity, we must verify its identity, structure, and authorised representatives.
We may request the following information and documents:
- Full legal name, registration number, and registered address of the entity.
- Extract from the official company register or equivalent proof of incorporation.
- Details of authorised representatives, including valid identity documents and liveness checks.
- Information on the ownership structure, including shareholders and beneficial owners.
- Proof of address for the entity and its beneficial owners.
- Details on the nature of the business, purpose of the account, and expected activity.
- Declarations required under applicable AML/CFT laws, such as confirmation that no beneficial owner, director, or representative is a Politically Exposed Person.
Depending on the jurisdiction, the nature of the business, or the risk assessment outcome, we may request additional documents, such as financial statements, proof of funds, or source of wealth information for beneficial owners.
9. Which third-party providers do we use for data verification and monitoring?
To verify customer identities, we work with trusted and reputable service providers that meet high data protection and compliance standards.
Currently, we use Sum and Substance Ltd. (Sumsub) for identity verification and customer due diligence.
For cryptocurrency transaction monitoring, we engage specialized blockchain analytics providers that help us detect and prevent transactions potentially linked to money laundering, terrorist financing, or other illicit activities.
These providers operate in accordance with applicable data protection laws and support us in fulfilling our AML/CFT obligations.
10. Who cannot use our services?
We do not provide services to:
- Users who do not complete or fail our identity verification process.
- Users residing in jurisdictions where our services are restricted by law, international sanctions, or our internal risk policies.
- Users located in countries or territories where a specific license or permit is required to offer our services and we do not hold such authorization.
- Users whose activity, background, or source of funds presents an unacceptable risk of money laundering, terrorist financing, or other illicit activity.
We maintain and update a list of high-risk or restricted jurisdictions in accordance with applicable laws, regulatory guidance, and our internal risk assessment procedures. This list is reviewed regularly and may change without prior notice.
11. Why can’t I use Monero, Zcash, or other privacy coins on INit?
For regulatory and security reasons, INit does not support anonymous or privacy-focused cryptocurrencies (also called anonymity-enhanced crypto-assets, or AECs). Examples include Monero (XMR), Zcash (ZEC) in shielded mode, Dash (PrivateSend), Grin, Beam, and similar assets.
These coins are designed to hide the sender, recipient, or transaction amount, which makes it impossible for us to apply the legally required Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and security checks. Supporting such assets would expose both INit and its customers to unacceptable compliance risks.
Any attempt to use Monero, Zcash, or similar assets on our platform will be blocked.
12. How long do we keep your data?
We retain your personal data for as long as necessary to provide our services and to meet our legal, regulatory, and compliance obligations.
The retention period depends on the requirements of the applicable laws in the jurisdiction of the Company providing the service.
In certain cases, we may need to store your data for a longer period if required by law, regulatory requests, or other legitimate business or legal purposes. Once the retention period expires, your data will be securely deleted or anonymized in accordance with our data protection standards.
13. To whom can we share your data?
We may share your personal data with competent supervisory and law enforcement authorities when required by applicable laws and regulations, or when necessary to prevent, detect, and investigate money laundering, terrorist financing, or other illegal activities.
Any such disclosure will be made strictly in accordance with legal requirements, ensuring that only the necessary information is provided and that your rights under applicable data protection laws are respected.
14. How often will this Policy change?
We review and update this Policy as needed to remain compliant with applicable laws and regulatory requirements. Changes may be made without prior notice, and the updated version will be published on our Website.
We encourage you to review this Policy periodically to stay informed about our current AML/CFT measures. Your continued use of our Services after any updates means you accept the revised Policy.
15. Our contacts
If you have any questions, comments, or requests regarding this AML/CFT Policy, please contact us via email at [email protected].
For security and compliance reasons, certain operational procedures and internal AML/CFT controls are not disclosed in this public Policy but are documented in our internal AML/CFT framework, available to competent authorities upon lawful request.
We are committed to ensuring transparent communication with users and full cooperation with supervisory and law enforcement authorities in accordance with applicable laws and regulations.
