AML / KYC Policy

Last updated: January 1, 2025

Short version: CryptoSwapPro screens every transaction for money laundering and sanctions violations. Under $10K/day needs no ID. Above that, we ask for identity documents as required by law.

1. Introduction

CryptoSwapPro operates under international AML/CTF standards, including FATF's 40 Recommendations for virtual asset service providers (VASPs). This page describes what we check, what we block, and when we ask for identification.

We apply these rules because we have to by law and because we don't want our platform used for financial crime. The policy is enforced by automated screening on every transaction, not just spot checks.

2. Know Your Customer (KYC) Procedures

2.1 No-KYC Tier (up to $10,000/day)

For exchange transactions up to the equivalent of $10,000 USD per day, we do not require identity verification. Users only need to provide a valid destination wallet address.

2.2 Standard KYC (above $10,000 up to $100,000)

Transactions exceeding $10,000 USD per day require basic identity verification:

2.3 Enhanced Due Diligence (above $100,000)

For transactions exceeding $100,000 USD, we apply Enhanced Due Diligence (EDD) procedures in accordance with FATF Recommendation 10:

3. Prohibited Activities

We do not facilitate transactions associated with:

4. Transaction Monitoring

We employ automated and manual transaction monitoring to detect suspicious patterns. Our monitoring system is powered by blockchain analytics technology (including tools similar to Chainalysis and/or Elliptic) to analyze:

Any wallet address associated with a risk score exceeding our threshold will be flagged for manual review. Transactions may be delayed or rejected pending investigation.

5. Suspicious Activity Reporting

When we identify suspicious activity, we are required to file a Suspicious Activity Report (SAR) with the appropriate financial intelligence unit. We will cooperate fully with law enforcement authorities and provide all requested records, to the extent permitted by law.

6. Sanctions Compliance

We screen all users and transactions against international sanctions lists including:

We do not provide services to individuals or entities located in, or operating from, sanctioned jurisdictions including but not limited to: North Korea, Iran, Cuba, Syria, and certain regions of Ukraine.

7. Fund Freezing Procedures

In cases where we identify funds that are potentially linked to criminal activity or sanctions violations, we reserve the right to:

8. Record Keeping

In accordance with FATF Recommendation 11, we retain the following records for a minimum of 5 years:

9. Compliance Officer

We have designated a Compliance Officer responsible for overseeing this AML/KYC program, ensuring it is kept up to date with regulatory developments, and training relevant staff on AML obligations.

10. Politically Exposed Persons (PEPs)

We apply enhanced due diligence to customers identified as Politically Exposed Persons (PEPs) or their close associates, in accordance with FATF Recommendation 12. PEPs are subject to senior management approval for establishing or continuing business relationships.

11. High-Risk Jurisdictions

Customers from jurisdictions identified by FATF as having strategic AML/CFT deficiencies are subject to enhanced scrutiny. We maintain an up-to-date list of high-risk countries and apply proportionate counter-measures.

12. Training and Awareness

All relevant personnel receive regular training on AML/CTF obligations, including how to identify suspicious activity, the correct escalation procedures, and the legal consequences of non-compliance.

13. Policy Updates

This policy is reviewed at least annually and updated as necessary to reflect changes in applicable law, FATF guidance, or our business operations. Material changes will be communicated via our website.

14. Contact

For AML/KYC inquiries or to submit documentation, please contact our Compliance Team:

📧 [email protected]
For general support: [email protected]

Notice: This policy is for informational purposes. CryptoSwapPro reserves the right to request additional verification at any time and to decline service to any user at our discretion in compliance with applicable law.

AML compliance and no-KYC: how they coexist

A common misconception is that "no KYC" means "no compliance." This is incorrect. Anti-Money Laundering compliance and identity verification are two separate things, and confusing them leads to poor security decisions from both sides of an exchange.

AML compliance means screening every transaction for connections to criminal activity — dark web markets, ransomware wallets, sanctioned entities, mixer outputs. This can be done entirely via blockchain analytics without knowing the name of the person initiating the transaction. The blockchain is public: every address has a history, and that history is analyzable.

KYC (Know Your Customer) is a separate layer required only when transaction volumes reach thresholds defined by financial regulations — in most jurisdictions, $10,000 per day is the standard threshold. Below that threshold, the legal requirement is risk-based screening of the transaction, not of the person. CryptoSwapPro does the former on 100% of transactions and the latter only when legally required.

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Blockchain analytics vs identity checks
Chainalysis and similar tools score wallet addresses based on their transaction history on-chain. This catches funds from known criminal wallets, mixer outputs, and ransomware payments — without requiring you to submit a passport.
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FATF Recommendation 10 in plain terms
FATF Recommendation 10 requires financial institutions to apply customer due diligence — but it explicitly allows a risk-based approach. For small transactions with no red flags, the required diligence is the transaction screening we already apply.
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What triggers a manual review
Transactions flagged by our automated system go to a human compliance officer before processing. Triggers include: high-risk jurisdiction of origin, wallet associated with a known scam, mixer input in the transaction chain, or transaction patterns consistent with structuring.
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Sanctioned country handling
IP addresses from OFAC-sanctioned jurisdictions are blocked at the infrastructure level. We do not process exchanges initiated from Iran, North Korea, Cuba, Syria, or active conflict zones in Ukraine. This is not a business decision — it is a legal requirement.

AML FAQ for users

Will AML screening delay my exchange?
No. Chainalysis screening takes milliseconds and runs in parallel with the exchange routing. You will not see any delay from AML checks under normal circumstances. If a transaction requires manual review — which affects less than 0.3% of exchanges — you will receive a notification and an estimated wait time.
My funds came from a DEX — will that cause issues?
Funds from legitimate decentralized exchanges (Uniswap, Curve, dYdX) are not flagged. Funds that have passed through privacy-enhancing services (mixers, tumblers, specific privacy coin bridges) may be flagged. If you are unsure about the origin of your funds, contact support before initiating a large exchange.
What happens if my transaction is flagged?
Your funds are held pending a compliance review. We will contact you via the Telegram ID or email you provide (if any) and request documentation. If the transaction is cleared, it is processed immediately. If it cannot be cleared, funds are returned to your refund address minus any blockchain fees. We do not confiscate funds.
Can I exchange Monero (XMR) on your platform?
Yes, we support Monero exchanges. XMR transactions receive additional scrutiny given the privacy features of the Monero protocol, but they are not automatically blocked. Monero-to-Monero exchanges under $10,000/day are processed normally. For larger amounts involving XMR, basic KYC may be required.
I received a compliance request — what documentation do I need?
Standard requests ask for a brief explanation of the source of funds (e.g., "purchased on Coinbase on [date]," "received as salary from [company]") and supporting documentation. We do not ask for bank statements or tax returns except in cases involving very large amounts or complex transaction patterns.
⚡ Exchange Crypto — AML-Compliant, No Registration
No KYC under $10,000/day · Chainalysis screening · FATF-compliant