Introduction

LLC “GreenCash” maintains a strict Anti-Money-Laundering (AML) and Counter-Terrorist-Financing (CTF) policy, operating in full compliance with the legislation of the Kyrgyz Republic and with international standards. The goal of this policy is to prevent use of the platform for illicit activity, to guarantee transparency of operations, and to protect the reputation of the company and its clients. The policy is built on industry best practices and embraces a comprehensive set of measures covering Know Your Customer (KYC), transaction monitoring, reporting and other areas.
GreenCash LLC operates strictly under Law No. 87 of 6 August 2018 of the Kyrgyz Republic “On Counteracting the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism,” which is overseen by the Ministry of Finance of the Kyrgyz Republic and enforced through the State Financial Intelligence Service (SFIS).

1. KYC Procedures

1.1 Collection of client data
When registering and servicing clients, GreenCash rigorously applies KYC requirements, collecting and verifying exhaustive data necessary to identify a person. A client must supply full name, date of birth, citizenship, and an identity document (passport or other ID showing number, series and date of issue, plus photo), together with current residential address and contact information. The client must also state the nature of their business and the source of their funds. These requirements match international standards—including FATF recommendations—and national legislation (Law No. 87 of 6 August 2018).
1.2 Customer identity verification
The company validates the authenticity of all documents and data, using advanced methods such as passport checks against state databases (where possible) and biometric confirmation. In necessary cases a client may be asked for a selfie holding the document or a short video call. GreenCash denies access to its services until the identity has been successfully confirmed under its Customer Identification Program (CIP). Documents in foreign languages must be translated and certified.
1.3 Risk-based client categorization
After KYC, GreenCash assigns every client a risk level (low, medium, high) based on sanctions-list screening, PEP status, country of residence or business registration, intended use of the service and expected transaction volumes. High-risk clients—e.g., PEPs, persons from weak-AML jurisdictions or with unclear funding sources—are subject to Enhanced Due Diligence (EDD): additional documents (proof of address, bank statements, information on beneficiaries, etc.) are collected and executive approval is required before service is provided.

2. Transaction Monitoring

2.1 Automated analysis
GreenCash monitors every client transaction via a dedicated AML platform that analyses blockchain flows against risk criteria. Movements on wallets linked to the platform are matched against known patterns and databases for all major assets supported, including ERC-20 tokens.
2.2 Detection of suspicious activity
Each transaction is scored on factors such as amount, frequency, sequence, linked wallets and geography. Unusual behavior (e.g., atypically large sums, use of mixers, structuring into many small transfers, links to high-risk jurisdictions) triggers alerts. Addresses are also checked for prior ties to darknet markets or known illicit schemes.
2.3 Use of sanctions lists
The monitoring tool is integrated with global sanctions databases (UN, OFAC, EU, etc.). If an address matches a sanctioned entity or one linked to terrorist organizations, the transaction is immediately flagged.
2.4 Response to alerts
Flagged transactions undergo manual review by the compliance team, which may request additional information (economic purpose, proof of funds). Transactions can be temporarily frozen while the review is underway. If suspicions persist, a Suspicious Activity Report (SAR) is prepared (see section 3).

3. Reporting Procedures

3.1 Suspicious Activity Reports (SARs)
When a transaction or activity appears dubious, GreenCash drafts a SAR detailing client data, description of the activity, specific risk indicators and internal measures taken (e.g., freezing the funds). The SAR is approved by the head of compliance (and legal, if needed) and submitted to the State Financial Intelligence Service.
3.2 Submission to regulators
SARs are sent promptly—no later than three business days after detection—to the SFIS and, when applicable, to the State Service for Regulation and Supervision of the Financial Market (Financial Supervision Service).
3.3 Regular reporting and cooperation
Besides individual SARs, GreenCash files periodic AML reports (quarterly or annual, as required) covering implemented KYC measures and statistics on detected cases. The company maintains a register of all SARs and provides additional information upon lawful requests from authorities.

4. Sanctions Lists and Screening

4.1 Screening new clients
During onboarding every client is screened against up-to-date sanctions lists (UN, OFAC SDN, EU, UK and others). Automated systems compare personal data with these databases.
4.2 Ongoing screening of existing clients
The client base is re-screened at least daily. If a current client becomes sanctioned, GreenCash immediately blocks their operations, informs management and regulators, and decides further actions under applicable law.
4.3 Screening of transactions
All incoming and outgoing transactions are checked so that sanctioned parties cannot participate. Transfers involving addresses linked to sanctioned entities or high-risk countries are blocked pending investigation.
4.4 Alignment with international AML standards
Combining sanctions, terrorist, PEP and adverse-media checks ensures full-spectrum screening in line with FATF guidance and leading financial-industry practice.

5. Handling Politically Exposed Persons (PEPs)

5.1 Identification
Clients must declare PEP status for themselves, close family or associates; GreenCash also screens dedicated PEP databases.
5.2 Enhanced Due Diligence
PEPs undergo EDD—additional documents (e.g., income declarations, bank statements, bank references) are required to verify that their funds are legitimate.
5.3 Ongoing monitoring
Transactions by PEPs are subject to lower alert thresholds and a “four-eyes” review (automated plus manual). Any doubts can prompt a SAR.
5.4 Governance and reviews
Opening or retaining a PEP account needs senior-management approval. PEP status is reviewed periodically, and all related data are kept highly confidential.

6. Requirements of Kyrgyz Legislation

6.1 Licensing and local regulations
GreenCash conducts its business under the Law of the Kyrgyz Republic “On Virtual Assets” No. 12 of 21 January 2022 and holds the required crypto-exchange licence. The company is recorded in the Unified State Register of Crypto-Currency Exchanges and meets minimum-capital requirements.
6.2 AML/CTF compliance
Procedures for client identification, transaction monitoring, record-keeping and SAR filing fully meet national AML/CTF laws and FATF recommendations. Internal policies are updated promptly to reflect legal or standards changes.
6.3 Interaction with authorities
An AML Compliance Officer is appointed as the contact point for the Financial Supervision Service and the SFIS. GreenCash is open to scheduled and ad-hoc inspections and supplies all requested documents.
6.4 Sector-specific rules
The company observes the Travel Rule for crypto transfers above 85 000 KGS (~ USD 1 000), collects and transmits sender/recipient data, and reports large transactions above set thresholds even if they are not suspicious. Tax-law obligations are also met.

7. Additional Elements

7.1 Client-data retention policy
All KYC documents, questionnaires, communications and transaction logs are stored in encrypted, access-controlled databases located mainly in the Kyrgyz Republic. Records are retained for at least five years after the end of the client relationship (or longer if required). Regular backups and leak-prevention measures are in place.
7.2 Fraud-prevention measures
GreenCash employs two-factor authentication (2FA), device/IP anomaly detection, and real-time behavioural analytics to combat phishing, account take-overs and other fraud. Sudden asset liquidations or unusual withdrawals trigger reviews. Users receive education on common scams, and the company cooperates with law-enforcement when fraud is suspected. Staff receive ongoing training in fraud detection.