AML Policy

This AML Policy describes the risk-based anti-money-laundering, counter-terrorist-financing and sanctions controls applied to crypto-to-crypto exchange activity through Private Crypto Swap.

Our standard exchange flow is designed so that eligible orders can begin without routine KYC. This does not remove transaction screening or risk controls. A specific order may require additional review when its blockchain history, counterparties, transaction pattern or other available information indicates elevated risk.

Purpose of the Policy

The purpose of our AML controls is to reduce the risk that the service is used to process proceeds of crime, stolen cryptocurrency, fraud, sanctions evasion, terrorist financing or other prohibited activity.

The controls are applied on a risk basis. Not every transaction requires the same level of review, and a standard order can proceed through the normal exchange flow when no material risk indicator is identified.

Compliance and anti-money-laundering risk review concept

Transaction Risk Screening

We may evaluate information connected with an exchange order, including:

sending and receiving assets;

blockchain networks;

wallet addresses;

transaction hashes;

amount and transaction pattern;

publicly available blockchain history;

sanctions or restricted-party exposure;

indicators of theft, fraud, ransomware or other illicit activity;

technical and security signals associated with the order.

Blockchain analytics or other specialist service providers may be used to support this assessment.

When Additional Review May Be Required

An order may be escalated for additional review when risk indicators are detected. Examples can include material exposure to sanctioned addresses, stolen funds, known fraud infrastructure, ransomware activity, suspicious transaction patterns or other high-risk sources identified through available screening data.

Additional review can also be triggered when information supplied for an order is inconsistent, when a transaction cannot be matched to the expected deposit, or when security systems detect behavior that requires manual investigation.

Verification and KYC Requests

Routine identity verification is not required at the start of every eligible standard order. However, we may request additional information when it is reasonably necessary to resolve a compliance or security concern.

Depending on the circumstances, requested information can include:

confirmation of control over a sending or receiving wallet;

transaction details or screenshots needed to identify a payment;

explanation of the source or purpose of funds;

proof of source of funds;

identity information or supporting documents where enhanced verification is required.

The scope of a request should be proportionate to the risk being reviewed.

Actions We May Take

If an order requires review, processing may be paused while the relevant information is assessed. Depending on the outcome, we may:

allow the order to continue;

request additional information;

reject or cancel the transaction;

restrict access to the service;

return funds where operationally and legally possible;

retain information required for compliance or dispute handling;

make a report to a competent authority when required by applicable law.

Any return of cryptocurrency is subject to blockchain conditions, address compatibility, network fees and legal or compliance restrictions that may apply to the transaction.

Prohibited Use

The service must not be used knowingly to exchange cryptocurrency connected with:

proceeds of crime;

theft or unauthorized access to wallets;

fraud or scams;

ransomware or extortion;

terrorist financing;

sanctions evasion;

trafficking or exploitation;

other activity prohibited by applicable law.

Users are responsible for ensuring that they have lawful control of the funds they send and that their use of the service is permitted in their jurisdiction.

Sanctions Controls

We may screen wallet exposure and other available information against sanctions-related risk indicators. Transactions involving sanctioned persons, entities, addresses or jurisdictions may be rejected, paused or escalated where required by applicable restrictions.

The service does not guarantee that every blockchain address can be conclusively attributed to a specific person or organization. Risk decisions may therefore consider multiple signals rather than a single data point.

Privacy and Retention

Information obtained through AML or security review is handled in accordance with our Privacy Policy. Compliance-related data may be retained for the period reasonably required to resolve the order, prevent abuse, meet legal obligations and respond to lawful requests.

Policy Updates

We may update this AML Policy as our risk controls, supported services, legal obligations or operational processes change. The version published on the website is the current policy.

AML and Compliance Contact

Questions about a specific order or a compliance review can be submitted through the Contacts page. Include the order identifier and relevant transaction hash when available, but never send wallet seed phrases, private keys or passwords.

Contact Support