AML & Acceptable Use Policy

Collext is committed to preventing its Services from being used for money laundering, terrorist financing, sanctions evasion, fraud, or any other financial crime. This policy explains the measures we take and what we expect from users. It forms part of our Terms of Service.

We design our controls around the risks of a peer-to-peer marketplace: the birr side of every trade moves between users' own bank and mobile-money accounts, so making sure people pay and are paid from accounts in their own names is central to keeping the marketplace safe.

We do not allow anonymous accounts. Every account:

• is held by one identifiable adult, who must confirm their email address before using the Services;
• must have a Telebirr number in the user's own name before trading; and
• may receive payments only into bank and mobile-money accounts held in the user's own name.

We may ask you to verify your identity at any time, and we will do so where the law requires or where our risk assessment indicates it. That may include asking for a government-issued identity document, a photo of yourself, proof of address, proof that a payment account is yours, or information about the source of your funds. We may limit or suspend your account until verification is complete, and we may close accounts that do not complete it.

We monitor activity on the Services to detect patterns that may indicate financial crime or fraud. Our checks cover, or may cover:

• every payment receipt submitted for an order, including that it was paid to the right account, after the order opened, and that it has not been used before;
• unusual trading volumes or frequencies compared with an account's history;
• orders that are repeatedly opened and abandoned, or trades that appear to have no economic purpose;
• multiple accounts that appear to be controlled by the same person;
• deposits from, and withdrawals to, blockchain addresses associated with illicit activity or sanctions; and
• activity that looks like an attempt to split transactions to avoid limits or checks.

Withdrawals and other transactions may be reviewed by our staff before they are processed.

You must not use the Services for, or in connection with:

• money laundering, terrorist financing, or any proceeds of crime;
• evading sanctions, or dealing with sanctioned persons or territories;
• fraud, scams, or impersonation, including fake or altered receipts;
• paying or receiving payment on behalf of other people (acting as a "money mule"), or using accounts that are not in your name;
• splitting transactions to avoid limits, reviews or reporting;
• trading for a business, or on behalf of others, without our written agreement;
• illegal gambling, illegal goods or services, or any activity that is unlawful where you or your counterparty are; or
• hiding, disguising or misrepresenting the origin or ownership of funds.

The full list of things you must not do on the Services is in section 13 of our Terms of Service.

If we suspect a breach of this policy, or are required to by law, we may:

• ask you for information or documents and restrict your account until you provide them;
• delay, refuse or reverse trades, deposits and withdrawals;
• hold balances while we investigate;
• close your account; and
• report the activity to the relevant authorities, including the financial intelligence unit and law enforcement.

The law may prevent us from telling you that we have made a report or that an investigation is under way. We will not be liable to you for actions we take in good faith to comply with this policy or the law.

We do not provide the Services to persons or entities subject to sanctions administered by the United Nations or other authorities whose sanctions apply to us, or to anyone acting on their behalf, or for any transaction involving a sanctioned territory. We may screen users and blockchain addresses against sanctions information, and we will block or freeze funds where the law requires.

We keep records of user identification, trades, payment proofs, verification results, deposits, withdrawals and the reviews we carry out, for as long as the law requires, including after an account is closed. Our Privacy Policy explains how we protect these records.

We cooperate with courts, regulators and law-enforcement authorities that make lawful requests for information, and we may freeze or return funds when lawfully directed to do so. We review each request to make sure it is valid before we disclose information.

Staff who review trades, disputes and withdrawals look for signs of financial crime and fraud, and escalate what they find. Staff actions on user accounts and balances are logged. We review this policy and our controls regularly, and update them as risks, technology and the law change.

If you think you have been targeted by a scam, that someone has paid you with money that is not theirs, or that another user is breaking this policy, stop the trade if you can and contact us at [email protected], with the order ID if there is one. Do not release USDT for a payment you are unsure about. Open a dispute on the order instead.