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Swapgate team
July 8, 2024
~5 min read

AML Policy

Swapgate.io Anti-Money Laundering, Anti-Terrorist Financing Policy (hereinafter referred to as AML Policy) and Know Your Customer Policy (hereinafter referred to as the “KYC Policy”) is intended to prevent and reduce the possible risks of the swapgate.io service participating in any illegal activity.

International laws and regulators, as well as the Fifth Anti-Money Laundering and Anti-Terrorism Financing Directive (5AMLD), require the swapgate.io service to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, weapons of mass destruction, corruption and bribery, as well as taking action in case of any form of suspicious activities and activity of its Users.

The exchange office, as a service provider of virtual/cryptocurrency assets, is obliged to verify all suspicious transactions of virtual/cryptocurrency assets. During the verification, among other things, it is necessary to carry out user identification (KYC) and establish the origin of the virtual/cryptocurrency asset. Also, during the period of verification of the transaction, the virtual/cryptocurrency asset must be kept on the balance sheet.

  1. By creating an order on the website, the Client agrees that an AML/KYC check may be carried out against him.

1.1. The AML/KYC verification procedure for clients and transactions is carried out by the AML officer of the swapgate.io service, as well as by our liquidity provider, namely the cryptocurrency exchange.

1.2.As part of the AML/KYC check, the Client consents to the processing and storage of his personal data, as well as, if necessary, to the transfer of this data to the liquidity provider, namely the AML officer of the cryptocurrency exchange.

1.3. The AML/KYC procedure includes a set of developed measures:

  • Performing continuous monitoring of transactions passing through the swapgate.io service;
  • Appointment of a responsible person (Money Laundering Reporting Officer);
  • Risk-based approach;
  • Customer Due Diligence;
  • Improving the professional skills and knowledge of swapgate.io service employees;
  • Interaction with government authorities in cases established by law;
  • Bookkeeping, accounting, record keeping.

      2. If, based on the results of the analysis of AML-cryptocurrency assets, a risk higher than 40% is identified, or any of the following labels are received:

  • DARK SERVICE
  • SCAM
  • STOLEN
  • MIXING (MIXER)
  • SEXTORTION
  • RANSOMWARE
  • HACK
  • PHISHING
  • TERRORISM FINANCING
  • FRAUD
  • BLACKLIST
  • STILL UNDER INVESTIGATION
  • CYBERCRIME ORGANIZATION
  • NARCOTICS
  • CHILD ABUSE
  • HUMAN TRAFFICKING
  • SANCTIONS

And other high-risk assets, the Client’s transaction may be frozen for an indefinite period until complete identification verification (KYC) is completed.

2.1 Upon receipt of a service request from our liquidity provider, namely a cryptocurrency exchange, the Client’s transaction may be frozen indefinitely until complete identification verification (KYC) is completed.

2.2 Upon receipt of a request from the competent authorities, the Client’s transaction may be frozen for an indefinite period until complete completion of identity verification (KYC).

2.3  If any suspicious activity is detected by the AML officer of the swapgate.io service, the Client’s transaction may be frozen for an indefinite period until complete identification verification (KYC) is completed.

3. Documents for passing KYC verification:

To confirm the origin of funds, we ask you to fully answer the following questions:

  • Through which platform did the funds reach you? Please provide screenshots of the withdrawal history of the sender’s wallet/platform, as well as links to both transactions in the explorer
  • What service did you receive funds for?
  • What was the amount of the transaction, as well as the date and time it was carried out
  • Which contact person did you use to communicate with the sender of the funds? Please provide screenshots of correspondence with the sender, where we can see confirmation of sending funds.

We also ask you to provide the following materials:

  • Photo of one of the documents (passport, ID card or driver’s license)
  • Selfie with this document and a sheet of paper on which today’s date and signature will be written by hand

If necessary, the service has the right to additionally request any other documents not listed in this section. All submitted images (scans, photos, screenshots) must be in jpeg or png format.

3.1 The time frame for reviewing documents for passing a KYC check is individual for each case and is not regulated by time.

3.2 Return of blocked assets is possible only after passing a KYC check.

3.3 User assets that have not passed AML verification cannot be exchanged.

3.4 Based on the results of a positive KYC check, the client will be refunded with a commission of 5%.

   4. Please note that our service reserves the right to charge an additional fee of up to 5% on transactions if they have high-risk characteristics, such as:

  • DARK SERVICE
  • SCAM
  • STOLEN
  • MIXING (MIXER)
  • SEXTORTION
  • RANSOMWARE
  • HACK
  • PHISHING
  • TERRORISM FINANCING
  • FRAUD
  • BLACKLIST
  • STILL UNDER INVESTIGATION
  • CYBERCRIME ORGANIZATION
  • NARCOTICS
  • CHILD ABUSE
  • HUMAN TRAFFICKING
  • SANCTIONS

This additional fee is applied to compensate for the additional analysis and risk mitigation measures required to process high-risk transactions.

5. The return of assets is not possible if a request has been received for these assets from the competent authorities or a seizure/blocking has been imposed by other departments of any jurisdiction (in this case, the blocked asset can be passed as material evidence). And also by decision to withhold funds by the liquidity provider.

6. Return of assets is not possible if the Client does not provide the information requested by the swapgate.io AML Officer by email within 30 calendar days.

7. Blocking is also carried out when sending assets from the following exchanges: NOBITEX, Garantex, Tornado Cash, Hydra, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, Commex, as well as from any Iranian platforms and other platforms of prohibited/sanctioned countries and operations from DarkMarket resources.

8. The liquidity provider, the initiator of the blocking, has the right to refuse to pay out the frozen funds after passing the AML check in the cases described in clause 2, clause 2.3 and clause 7.

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