Service and Technology LLC (hereinafter — the “Company”) is a digital asset service provider, a resident of the Technological Park of Software Products and Information Technologies (IT Park Dushanbe). The Company adheres to strict Anti-Money Laundering (AML) and Know Your Customer (KYC) standards.
This policy is developed in accordance with the Regulation on the Technological Park (Resolution of the Government of the Republic of Tajikistan No. 440 of 31 July 2024), the legislation of the Republic of Tajikistan and the international FATF standards.
Our goal: To ensure transparency of financial transactions and prevent the use of the Platform for laundering criminal proceeds, financing terrorism and other unlawful acts.
1. Legal Framework
The Company operates in accordance with:
- Resolution of the Government of the RT No. 440 of 31.07.2024 — Regulation on the Technological Park of Software Products and Information Technologies (clauses 63-64 — AML/KYC requirements for service providers)
- Law of the RT “On the Technological Park” — the legal basis for the IT Park and its residents
- Law of the RT “On Counteracting the Legalization (Laundering) of Proceeds of Crime and the Financing of Terrorism”
- Recommendations of the Financial Action Task Force (FATF)
- Requirements of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG)
- Requirements of the National Bank of Tajikistan
Requirements of clause 63 of the IT Park Regulation:
A digital asset service provider must appoint an officer responsible for AML/CFT compliance, ensure customer identification, sanctions-list screening and transaction monitoring.
2. What is KYC
KYC (Know Your Customer) is the procedure for identifying and verifying a customer's identity. It includes:
- Customer Identification (CIP): collecting the customer's basic information
- Customer Due Diligence (CDD): assessing the risks associated with the customer
- Enhanced Due Diligence (EDD): additional checks for higher-risk customers
- Ongoing monitoring: tracking transactions and updating customer data
3. Customer Verification
Important: All operations on the platform require mandatory identity verification with a selfie holding the document.
Standard Verification level
Mandatory requirements for all customers:
- Registration with email
- Phone number confirmation
- Upload of an identity document (passport)
- Photo (selfie) with the document
Limits:
- Exchange up to 50,000 TJS per day
- Exchange up to 500,000 TJS per month
Premium Enhanced level
Additional requirements:
- All standard-level requirements
- Proof of residential address
- Proof of source of funds
- Video verification (if required)
Limits:
- Individual limits
- Priority support
4. Required Documents
| Document | Description |
|---|---|
| RT citizen passport | Primary verification document. Photos of all pages containing data. |
| International passport | For foreign nationals. Pages with photo and data. |
| Selfie with document | A photo of the face holding the document. Data must be legible. |
| Proof of address | Utility bill, bank statement (not older than 3 months) |
| Source of funds | Income certificate, declaration, contract, etc. |
5. What is AML
AML (Anti-Money Laundering) is a set of measures aimed at preventing the use of the financial system to legalize criminal proceeds.
Key elements of our AML program:
- Identification and verification of all customers
- Real-time transaction monitoring
- Sanctions-list screening
- Detection of suspicious transactions
- Reporting suspicious transactions to authorized bodies
- Keeping records and documentation
- Staff training
6. Transaction Monitoring
We carry out ongoing transaction monitoring to detect:
- Unusually large transactions
- Frequent small-amount transactions (structuring)
- Transactions with high-risk jurisdictions
- Transactions inconsistent with the customer profile
- Transactions with addresses linked to illegal activity
7. Cryptocurrency Address Screening
The Company uses specialized services to check cryptocurrency addresses for links to:
- Darknet markets
- Ransomware
- Fraud schemes
- Sanctioned persons
- Mixers and tumblers
- Other illegal activity
8. Higher-Risk Customers
Higher-risk customers requiring enhanced due diligence (EDD) include:
- Politically exposed persons (PEP): high-ranking public officials and their close relatives
- Residents of high-risk jurisdictions: countries on FATF lists
- Customers with high transaction volumes: operations significantly exceeding the usual profile
- Complex ownership structures: trusts, nominee companies
9. Right to Refuse Service
The Company reserves the right to refuse service or suspend operations in the event of:
- Failure to pass verification
- Provision of false or forged documents
- Suspicion of fraud or money laundering
- Presence on sanctions lists
- Refusal to provide requested information
- Other justified reasons
10. Reporting Suspicious Transactions
In accordance with the legislation of the Republic of Tajikistan, the Company is obliged to report suspicious transactions to the Department for Counteracting the Laundering of Proceeds and the Financing of Terrorism under the National Bank of Tajikistan.
We are not permitted to inform the customer that such a report has been filed.
11. Record Retention
In accordance with clause 64 of the Technological Park Regulation (Resolution No. 440) and AML/CFT legislation, we retain:
- Copies of customer documents — at least 5 years after the end of the business relationship
- Transaction records — at least 5 years from the date of the operation
- KYC/AML check results — at least 5 years
- Correspondence with customers — at least 5 years
- Documents confirming operations — at least 5 years (per clause 64 of the Regulation)
Important: The minimum data retention period — 5 years — is set by law and cannot be shortened at the customer's request.
12. Staff Training
All Company employees undergo regular training on:
- Detecting suspicious transactions
- KYC/CDD procedures
- Current legislative requirements
- New money-laundering methods
13. Compliance Officer
In accordance with clause 63 of the Technological Park Regulation, the Company has appointed an officer responsible for AML/CFT compliance (Compliance Officer), who:
- Ensures AML/KYC compliance in line with the IT Park Regulation
- Organizes customer identification and verification
- Screens customers against sanctions lists
- Monitors transactions
- Conducts internal reviews and audits
- Liaises with regulators (National Bank of the RT, Agency for Innovation and Digital Technologies)
- Organizes staff training
14. Contacts
For AML/KYC-related matters:
- Email: [email protected]
- Address: Republic of Tajikistan, Dushanbe, Mirzo Tursunzoda St, 27