Reading your ToS, I wouldn't say that you are really a no-KYC service. With truly no-KYC exchanges, there is no case when you keep the user's funds. There is an important difference between "In most cases" and "In all cases."
Also, what happens if the user does not want to go through KYC with you, and you still do not refund them? Where do such coins end up?
What does further communication with regulators and authorities look like?
2. Triggers for AML/KYC Procedures
AML/KYC checks may be initiated in the following situations:
if a wallet address involved in the transaction appears on sanctions or blacklists (including public watchlists and compliance tools),
upon a substantiated request from competent authorities or regulators,
when a transaction is flagged during internal risk assessments related to fraud, terrorist financing, or asset tracing.
4. Failure to Comply
If a user refuses to provide requested information during an AML/KYC review, Lizex.io may suspend or cancel the transaction. In most cases, funds will be returned to the original sending address, except where prevented by legal, technical, or compliance restrictions. Network expenses incurred during this process may be withheld.
