Anti-Money Laundering Policy

SwapIt operates an anti-money laundering (AML) and sanctions-compliance program proportionate to its role. We do not hold customer funds, open customer accounts, or take identity documents, so our program is built around the two things we do control: the addresses a swap involves, and whether we let a swap proceed.

This policy applies to every swap routed through SwapIt, whether it is a direct swap executed from your wallet or a backup swap handed to an exchange service provider, and to anyone using the website: individuals, businesses, and anyone acting on another party's behalf.

Where this policy and the Terms of Service differ, the Terms of Service govern your contract with us and this policy governs our compliance conduct.

SwapIt may not be used, directly or indirectly, for any of the following. Attempting any of it is a breach of our Terms and gets your swap blocked.

• Money laundering, terrorism financing, proliferation financing, or hiding the origin of funds.
• Evasion or circumvention of sanctions, export controls, or restricted-party rules.
• Receiving, moving, or cashing out proceeds of theft, hacking, phishing, wallet drainers, or ransomware.
• Trading with, or for the benefit of, darknet markets, darknet mixers, or sanctioned exchanges.
• Use of mixers, tumblers, or privacy-coin services to break the trail of funds that entered or leaves a swap.
• Fraud, market manipulation, card or bank-payment fraud, or scams of any kind.
• Illegal goods or services: narcotics, weapons, illegal gambling, human trafficking, or fraud tools.
• Self-laundering or layering: moving funds between wallets or chains with no lawful purpose.
• Any activity that is illegal in the jurisdiction you live in or the jurisdiction the funds came from.

We screen against the sanctions and restricted-party sources listed below. A match stops the swap.

• US Treasury OFAC Specially Designated Nationals (SDN) list, including the digital currency addresses OFAC publishes.
• United Nations Security Council consolidated sanctions list.
• European Union consolidated list of sanctioned persons and entities.
• UK Office of Financial Sanctions Implementation (OFSI) list.

SwapIt screens wallet addresses itself, and does not rely only on its exchange partners.

• Every recipient address you enter is checked against the sources in section 3 before a swap is allowed to start.
• Every deposit and payout address involved in a backup swap is checked the same way.
• Direct swaps are checked against the route the widget proposes before you are shown an approve prompt.
• Addresses are re-checked when a sanctions list changes, so an address that was clean when a swap was quoted can still be blocked before it runs.
• A match is a hard block: the swap does not run, and we do not process it manually as an exception.

For backup swaps, the exchange service provider runs its own checks on top of ours and may hold or refuse a transaction under its own AML and know-your-customer procedures. SwapIt screening does not override or replace a provider's decision.

We look at patterns, not just name matches. Activity that raises these flags is reviewed and may be blocked or reported.

• Structuring: many swaps kept just under a threshold, or one amount split into repeated smaller swaps.
• Rapid pass-through: funds arriving from one address and leaving to another within minutes with no other use.
• High value from a wallet with no prior activity, or a sudden jump from small to very large swaps.
• An address with known exposure to a sanctioned, stolen-funds, darknet, or mixer source.
• Repeated failed or abandoned swap attempts that look like route or threshold probing.
• A recipient address that changes repeatedly for the same intended destination.
• Any attempt to hide a destination: address swapping, manual overrides to a flagged address, or asking support to release a blocked swap.

If a swap or address is flagged, we may take any of the following:

• Block the swap before any funds leave your wallet.
• Refuse to route the swap and tell you that compliance prevented it, without disclosing the specific list match.
• Ask you for an explanation of the source and intended use of the funds.
• Hold a backup swap while the exchange service provider completes its own review.
• Refuse further service to the wallet or device involved.
• Report the activity to the competent authority in the relevant jurisdiction.

We do not release funds from a compliance hold on request, and we do not tell you which list produced a match where disclosure itself is restricted.

If you believe funds moved through SwapIt are stolen, coerced, or being laundered, tell us. Fast reports help, because on-chain tracing works best while funds are still moving.

Send to support@swapit.com with:

• The transaction hash and the chain it is on.
• The sending and receiving addresses involved.
• When it happened and what you think went wrong.
• Any reference number from the swap, if you have one.
• Your case or report number if you have already told the police or a financial regulator.

We will acknowledge reports, pass them to the exchange service provider that handled the swap where relevant, and cooperate with any lawful request from an authority. We cannot promise a recovery: once a swap settles on-chain it is usually irreversible, and we never hold the funds.

SwapIt responds to lawful requests from competent authorities. Because we do not hold customer funds or identity documents, the records we can produce are limited to what the service itself generates: routing attempts, swap references, and the compliance decisions we made.

Requests should come through official legal channels. We do not provide information on request from an individual, however urgent the claim, without a lawful basis.

We keep compliance records for as long as needed to meet legal obligations, resolve disputes, and evidence a screening decision: which address was checked, which sources were consulted, the result, and what we did about it.

We do not keep identity documents, because we never collect them. On-chain transaction history is public and outside our control, and remains visible to anyone after a swap settles.

This policy changes as sanctions lists and laws change. Material updates are posted on this page with a new "Last Updated" date; continuing to use SwapIt after a change means you accept it.

Questions about this policy, a blocked swap, or a compliance decision: support@swapit.com. Our Terms of Service, including eligibility and risk disclosure, are here.