AML/KYC Policy

Anti-Money Laundering Policy of Exswaping

Exswaping applies internal Anti-Money Laundering (AML) procedures to prevent the use of the service for illegal financial activities including money laundering, fraud, terrorist financing, and other prohibited activities.

The Service monitors transactions and applies risk-assessment procedures in accordance with industry standards for cryptocurrency exchange services.

Transaction Monitoring

All cryptocurrency transactions processed through the Service may be monitored using:

  • blockchain explorers
  • internal transaction monitoring tools
  • blockchain analytics services used for AML risk analysis

These tools allow the Service to detect transactions potentially associated with:

  • darknet markets
  • sanctioned entities
  • stolen funds
  • fraud schemes
  • mixing services
  • high-risk exchanges

Risk Score Model

Exswaping uses a Risk Score model to evaluate transaction risk levels.

Risk levels are categorized as follows:

  • Low Risk — up to 40%
  • Medium Risk — 40% – 60%
  • High Risk — above 60%

Transactions exceeding acceptable risk thresholds may be temporarily suspended for additional verification.

AML Verification

If a transaction is flagged by the risk-assessment system, the Service may temporarily suspend the exchange operation and request additional information from the user.

Verification may include:

  • confirmation of transaction hash (TXID)
  • confirmation of wallet ownership
  • verification of bank card ownership
  • additional information regarding the source of funds

The Service does not conduct mandatory full KYC procedures for all users.

However, verification may be requested in specific cases if required for AML compliance.

Verification Time

AML verification may take:

up to 24 hours for standard checks

up to 3 business days for extended review.

Refund Policy for AML Cases

If a transaction cannot be processed due to AML concerns:

  • funds may be returned to the sender's original address
  • a service fee of up to 5% may apply

The maximum refund commission does not exceed 100 USD equivalent.

For legitimate users whose funds pass AML verification and are not linked to illegal activities, only blockchain network fees may be deducted.

Address Management

To reduce transaction risks, the Service may use:

  • operational cryptocurrency addresses
  • unique deposit addresses generated for specific orders

Address management procedures may vary depending on the exchange direction and network.

Card Verification

For exchange directions involving bank cards, Exswaping requires bank card verification to confirm card ownership and prevent fraud.

Card verification procedures may include confirming the cardholder’s identity and validating card ownership.

Optional AML Check

Users may independently perform a preliminary AML check of their cryptocurrency address using public blockchain analysis tools before initiating an exchange operation.

If the user chooses not to perform such verification, they acknowledge that the Service may apply AML procedures during transaction processing.

Right to Refuse Service

Exswaping reserves the right to:

  • suspend suspicious transactions
  • refuse service
  • request additional information
  • return funds when necessary for AML compliance.

Prohibited Use

The Service must not be used for:

  • money laundering
  • terrorist financing
  • fraud
  • sanctions evasion
  • illegal financial activities