AML & sanctions policy
A proposed risk-based approach to responsible crypto swapping. Privacy does not mean ignoring financial crime.
For this interface preview only. Legal review and operator-specific details are required before a live launch.
Purpose and status
This is a draft policy for the Swapee interface preview, not proof of licensing, regulatory approval, or an operational compliance program. Before launch, the legal operator, jurisdictions, appointed compliance officer, exchange partners, screening vendors, escalation channels, and applicable legal duties must be established and reviewed by qualified counsel.
Risk-based screening
The proposed live service would assess transaction and wallet risk using sanctions screening, blockchain analysis, geography, behavior, and counterparties. Screening should occur before a deposit is requested where feasible, and continue through execution. A preliminary check is not a guarantee that no later review will be required.
Identity and source-of-funds checks
The service should collect only necessary information. However, identity verification, source-of-funds evidence, transaction purpose, or enhanced due diligence may be required where risk indicators, provider requirements, or applicable law justify it. Swapee does not promise that every transaction will be exempt from KYC. Refusing required checks may prevent completion.
Sanctions and prohibited activity
The live service must not knowingly facilitate sanctions violations, money laundering, terrorist financing, fraud, stolen funds, ransomware, trafficking, or other unlawful activity. Applicable sanctions lists and geographic restrictions must be identified by the operator. Attempts to evade screening or structure transactions to bypass controls are prohibited.
Reviews, restrictions, and reporting
Suspicious transactions may be declined, delayed, restricted, or reported when required by law. Legal obligations may restrict what can be disclosed about a review. No claim is made that funds can never be held or frozen. Any return of funds depends on legal restrictions, provider procedures, and the refund policy.
Records and access
The operator must define and publish retention periods based on its actual legal obligations and vendors. Compliance records should be encrypted, access-controlled, and available only to authorized personnel, necessary providers, and authorities where lawfully required.
Governance and requests
Before going live, the operator must appoint an accountable compliance lead, implement documented procedures and staff training, test controls, and provide a verified support and complaints channel. This preview has no operational compliance contact and does not process transactions.