AML and KYC policy
Draft for review. This document takes effect only after swapfrom publishes its operating company, registration and licence details on this page.
Purpose
swapfrom does not allow its service to be used for money laundering, terrorist financing, sanctions evasion or fraud. This policy describes the controls that apply to every swap.
Risk-based approach
Controls scale with risk. Most swaps pass automated screening with no extra step. Higher amounts and higher-risk indicators trigger additional checks.
Screening
Deposit addresses and transactions are screened against sanctions lists and known illicit activity, including theft, fraud, darknet markets and mixing services, using blockchain analytics.
Customer verification
When a swap exceeds a threshold or screening raises a concern, we ask for identity verification and, where relevant, source-of-funds information before the swap continues. We explain what we need whenever the law allows us to.
Prohibited use
Sanctioned persons and jurisdictions, proceeds of crime, routing through gambling accounts or third-party accounts, and any attempt to break the link between funds and their origin.
Liquidity partners
Liquidity is sourced only from exchanges and swap providers under partner API agreements. swapfrom does not route customer funds through personal accounts or gambling platforms.
Monitoring and reporting
Suspicious activity is reviewed by compliance staff and reported to the competent authority where the law requires. Funds linked to such activity may be held or returned as the law directs.
Records and governance
Records are kept for the period the law requires. A named compliance officer is appointed and listed here before the service opens.