Do exchange services require personal data? Are KYC/AML procedures mandatory?
Territorial jurisdiction:
Russia
Short answer:
Yes, exchange services collect personal data as part of mandatory KYC (Know Your Customer) and AML (Anti-Money Laundering) procedures.

Denis Polyakov
Head of Digital Economy practice at GMT Legal
Pursuant to the requirements of Federal Law No. 115-FZ "On Counteracting Legalization (Laundering) of Criminally Obtained Incomes" (Article 7), entities conducting transactions with monetary funds or other property, including the exchange of digital assets, are obliged to identify clients and apply measures to combat money laundering and terrorism financing (KYC/AML). This means that exchange services — both Russian and foreign — that seek to operate legally and maintain partnerships with payment systems or banks, request personal data. Typically, such data includes: • passport data or other identity documents; • a selfie with the identity document; • residential address; • Taxpayer Identification Number (TIN) or tax number (depending on jurisdiction); • information on the origin of funds — for large transactions. Therefore, cryptocurrency exchange without verification is becoming increasingly inaccessible, especially for transactions involving significant amounts.