1. Our Commitment
iDEX Exchange is committed to preventing the use of our platform for money laundering, terrorist financing, proliferation financing, and other financial crimes. Our AML/CFT program is designed to comply with applicable laws in the jurisdictions where we operate, and to prevent abuse of our services — even in the absence of identity collection.
2. Our Approach
Traditional AML relies on collecting identity documents (KYC). We take a different approach — one that meets our regulatory obligations while respecting your privacy:
- On-chain analytics — we use third-party blockchain analytics tools to screen incoming and outgoing transactions against risk indicators.
- Pattern detection — automated systems flag unusual deposit, withdrawal, or trading patterns.
- Address screening — transactions from or to sanctioned, darknet-linked, or known-fraud addresses are automatically blocked or flagged.
- Manual review — a compliance team reviews flagged activity and takes action where appropriate.
This risk-based approach is proportionate to the size, nature, and risk profile of our business.
3. Prohibited Use & Restricted Jurisdictions
You may not use iDEX Exchange if you are:
- Located in, or a resident of, any jurisdiction subject to comprehensive international sanctions;
- Located in any jurisdiction where crypto trading is prohibited by law;
- Listed on any sanctions list (UN, EU, US OFAC SDN, UK HMT, or similar);
- Acting on behalf of a person in any of the above categories.
We reserve the right to block access from specific jurisdictions and to refuse service to any user at our sole discretion.
4. Transaction Monitoring
We monitor account activity on an ongoing basis. Indicators that may trigger review include:
- Deposits originating from high-risk or sanctioned addresses;
- Rapid deposit-and-withdrawal patterns designed to obscure fund origin (layering);
- Structuring transactions to avoid internal thresholds;
- Trading activity inconsistent with a user's profile;
- Login patterns suggesting account takeover or credential sharing;
- Withdrawals to addresses linked to darknet markets, mixers, or ransomware wallets.
Flagged activity is reviewed by trained compliance staff. Additional verification, restriction, or termination may result.
5. Sanctions & Address Screening
All incoming and outgoing blockchain addresses are checked against:
- Public sanctions lists (OFAC, EU, UN, UK, and other applicable lists);
- Commercial blockchain analytics datasets covering sanctioned entities, darknet markets, and high-risk services;
- Internal blocklists based on previous abuse.
Transactions involving blocked addresses are rejected, and the account may be suspended pending review.
6. Suspicious Activity Reporting
Where required by applicable law, we file Suspicious Activity Reports (SARs) or equivalent disclosures with the relevant Financial Intelligence Unit (FIU). By law, we cannot notify you if a report has been filed about your account.
Internal policy prohibits "tipping off" — that is, revealing to any user that they are the subject of a report.
7. Account Freezing & Restriction
We may freeze, restrict, or close your account, and hold associated funds, if:
- We detect activity indicative of money laundering, terrorist financing, fraud, or other crime;
- We receive a valid legal order from a competent authority;
- We reasonably suspect a breach of these Terms, our Privacy Policy, or applicable law;
- Continued operation would expose iDEX Exchange or its users to legal or financial risk.
Where lawful and appropriate, we will contact affected users via their registered email. Funds linked to confirmed criminal activity may be permanently frozen or turned over to competent authorities.
8. Cooperation With Law Enforcement
We cooperate fully with law enforcement and regulatory authorities. Where we receive a valid legal request (subpoena, court order, mutual legal assistance treaty request), we will disclose the limited data we hold, including:
- Email address associated with the account;
- Registration and login timestamps;
- Transaction history on our platform;
- Deposit and withdrawal addresses;
- Session and IP logs where retained.
We do not disclose more than what is legally required, and we push back against overly broad requests.
9. Your Responsibilities
As a user, you agree to:
- Use iDEX Exchange only for lawful purposes;
- Not attempt to launder funds, evade sanctions, or finance illegal activity;
- Not use mixers, tumblers, or privacy coins to obscure the origin of funds deposited to your account, where such use is intended to evade detection;
- Respond promptly and truthfully to any compliance-related inquiry from us;
- Not create accounts on behalf of a third party or use an account you do not own.
Violation of these obligations may result in immediate account termination and reporting to authorities.
10. Recordkeeping
We maintain records of transactions, monitoring alerts, and compliance decisions for the minimum period required by applicable law (typically 5 years). Records are stored securely and access is restricted to authorized compliance personnel.
11. Internal Controls & Training
- Designated Compliance Officer responsible for the AML/CFT program;
- Regular independent review of monitoring rules and alerts;
- Ongoing training for relevant staff on AML typologies, sanctions, and reporting obligations;
- Segregation of duties between trading operations and compliance functions.
12. Contact
For compliance-related questions, or to report suspected abuse of our platform, please contact.
Note: this policy is a summary for users. Detailed internal procedures are maintained separately and are not published.