1. Introduction

Zavros Network (“we,” “our,” or “us”) is committed to maintaining the highest standards of integrity and preventing the use of our services for illicit activities. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the procedures and principles we employ to detect and prevent money laundering, terrorism financing, and other illegal financial activities.

Our framework is designed to comply with applicable laws and regulations, ensuring a secure and trustworthy environment for all users who wish to purchase cryptocurrency through our non-custodial service. By using Zavros.Network, you agree to abide by the terms outlined in this policy.

2. Our Risk-Based Approach

Zavros Network has implemented a sophisticated, risk-based approach to transaction monitoring. Our automated system analyzes transactions in real-time for characteristics that may indicate suspicious activity.

If a transaction is flagged by our system as potentially suspicious, it will be paused. The user will then be required to complete a KYC verification process to proceed. This approach allows the vast majority of our users to transact without interruption while effectively targeting high-risk activities.

3. KYC Verification Process

KYC verification is a mandatory process for any transaction flagged by our internal risk-management system. This process helps us confirm your identity and ensures the legitimacy of the transaction. Our verification process is designed to be as efficient as possible while remaining robust and compliant.

If your transaction requires verification, you will be asked to provide the following:

• A high-quality photo of a valid government-issued identification document. This can include a passport, national ID card, or driver’s license. The document must be current and not expired.
• A live selfie. This is used to match your face with the photo on your identification document, confirming your presence.
• Proof of Address (in some cases). For enhanced due diligence, we may request a recent utility bill or bank statement showing your name and address.

All personal data collected is handled in strict accordance with our Privacy Policy.

4. Identification of Suspicious Activity

Our monitoring system is calibrated to detect various red flags that may suggest illicit activities. A transaction may be flagged for reasons including, but not limited to:

• Unusual transaction sizes or patterns that deviate from typical user behavior.
• Attempts to obscure the source of funds or the transaction’s destination.
• Links to addresses or entities known to be associated with illicit activities.
• Transactions originating from or connected to high-risk jurisdictions.
• Inconsistent or suspicious information provided by the user.

5. Due Diligence Measures

Zavros Network employs two levels of due diligence based on our risk assessment:

• Standard Due Diligence (SDD): This is the baseline verification applied to transactions that are flagged by our system. It typically involves verifying the user’s identity through their ID document and a selfie.
• Enhanced Due Diligence (EDD): This more thorough level of verification is applied in high-risk scenarios. EDD may be required for users identified as Politically Exposed Persons (PEPs), transactions of a significantly large value, or activity linked to high-risk countries or behaviors. EDD may involve requests for additional documentation, such as proof of the source of funds.

6. Sanctions Compliance

Zavros Network is committed to complying with all applicable international sanctions. We screen user information and transaction data against sanctions lists from bodies such as the United Nations (UN), the European Union (EU), and the U.S. Office of Foreign Assets Control (OFAC).

We will refuse to process transactions for any individual or entity identified on these sanctions lists.

7. Refusal and Termination of Service

Zavros Network reserves the right to refuse or terminate a transaction at any stage if:

• A user fails or refuses to complete the mandatory KYC verification process.
• The provided documentation is found to be false, altered, or misleading.
• The transaction is confirmed to be associated with criminal activity.
• The user is identified as being on a sanctions list.

In such cases, any funds involved may be held and reported to the relevant authorities in accordance with legal requirements.

8. Contact and Inquiries

If you have any questions regarding our AML/KYC Policy or a transaction that has been paused for verification, please contact our support team at [email protected].