AML Policy for SwapETH.org
Effective date: September 14, 2026
This AML Policy describes the risk-based transaction-screening framework used by SwapETH.org. The service is presented under the public identity SwapETH.org / SwapETH Service.
Eligible swaps can begin without a persistent trading account, but that does not mean that every transaction is exempt from screening or that additional verification can never be requested.
For compliance questions, contact [email protected].
Purpose and Scope
SwapETH.org uses transaction screening and risk review to reduce exposure to illegal activity, fraud, sanctions evasion, stolen funds and other prohibited or high-risk use of the service.
This policy applies to exchange orders and related transaction activity processed through SwapETH.org. The exact checks performed can depend on the asset, blockchain network, transaction history, route, amount, risk indicators and other circumstances relevant to an order.
Risk-Based Transaction Screening
SwapETH.org does not apply one identical review to every transaction. Orders can be screened according to risk indicators connected with the source transaction, destination, blockchain activity, service route or other relevant information.
Risk screening can include analysis of public blockchain data and information available through service or compliance infrastructure. A transaction can receive additional review when risk indicators require it.
The existence of automated or manual screening does not mean that SwapETH.org guarantees that every prohibited transaction can be detected before it reaches the service.
When Additional Information May Be Requested
Additional information or verification may be requested when reasonably required to review a transaction or satisfy the service's compliance process.
Depending on the circumstances, the request can relate to:
- the source or purpose of funds;
- the relationship between a user and a sending or receiving wallet;
- the economic purpose of the transaction;
- transaction history or supporting information;
- identity or other verification where required by the risk review;
- clarification of unusual or inconsistent order activity.
Additional verification is not automatically required for every order. The scope of a request should be proportionate to the transaction and the identified risk.
Prohibited or Restricted Use
SwapETH.org must not be used to facilitate activity that is illegal or prohibited under applicable restrictions.
Examples of activity that can result in rejection or additional review include transactions reasonably associated with:
- money laundering or laundering the proceeds of crime;
- terrorist financing;
- sanctions evasion or prohibited sanctioned activity;
- fraud, scams or theft;
- ransomware, extortion or other criminal proceeds;
- stolen cryptocurrency or compromised-wallet activity;
- attempts to conceal the origin of funds for an unlawful purpose;
- prohibited goods or services;
- other activity that creates an unacceptable legal, compliance or security risk for the service.
This list is not exhaustive. A transaction can be restricted for another legitimate compliance or security reason even if the exact scenario is not listed above.
Risk Indicators
Risk review can consider indicators such as:
- links between the source transaction and addresses associated with theft, fraud or other illicit activity;
- sanctions-related exposure;
- unusual transaction patterns or attempts to avoid normal order controls;
- inconsistent information supplied during a review;
- transaction paths that materially increase the service's compliance risk;
- other blockchain or service signals relevant to the specific order.
No single indicator necessarily proves illegal activity. Risk indicators are evaluated in context.
Possible Review Outcomes
Depending on the stage of the order and the relevant route or provider conditions, a transaction under review can result in one or more of the following outcomes:
- normal processing after the review is completed;
- a request for additional information or verification;
- temporary delay while the transaction is reviewed;
- rejection or cancellation of an order before processing where possible;
- a refund or return review where a return is technically and operationally possible;
- restriction of further service use where the risk is considered unacceptable;
- preservation of information or cooperation with a valid legal or compliance request where required.
A refund is not an automatic outcome for every rejected or reviewed transaction. Blockchain irreversibility, network fees, route-provider rules, sanctions restrictions, legal obligations and the status of already executed transactions can affect what action is possible.
Refund and Return Reviews
When an order cannot proceed, any possible return of funds must be reviewed according to the actual transaction status, asset, network, destination, route and applicable restrictions.
SwapETH.org does not promise that funds can always be returned to the original sending address. Some sending platforms use pooled or intermediary addresses, and some blockchain transactions cannot simply be reversed.
Users should follow the instructions supplied by support or compliance for the specific order instead of sending a second transaction or attempting to reuse old deposit details.
User Responsibilities
Users are responsible for providing accurate order information and for using the service only for lawful purposes.
A user should:
- use funds they are authorized to control;
- provide truthful information when additional review is required;
- avoid using the service to evade legal or compliance restrictions;
- verify the source and destination networks before sending funds;
- not attempt to split or restructure transactions solely to avoid screening or limits;
- not send additional funds to an order under review unless instructed by support.
Providing false, misleading or incomplete information can delay or prevent completion of a review.
No Universal No-KYC Promise
SwapETH.org can allow eligible swaps to begin without creating a persistent trading account. This is different from promising that identity or other verification will never be requested.
Risk-based screening applies to transactions, and additional verification can be required when the circumstances justify it.
Marketing or support content should therefore not describe the service as guaranteed anonymous, universally no-KYC or exempt from transaction screening.
Public Blockchain Information
Blockchain transactions can be visible on public ledgers and through independent blockchain-analysis infrastructure. SwapETH.org can use public transaction information as part of a risk review.
A transaction recorded on a public blockchain cannot be deleted or changed by SwapETH.org simply because an order is later rejected or reviewed.
Privacy and Compliance Information
Information submitted during a compliance review is handled according to the Privacy Policy and applicable service requirements.
Compliance information should be requested only when relevant to the review and retained according to operational, security, compliance or legal needs rather than under an invented universal fixed period.
Policy Changes
This AML Policy can be updated when the service, transaction-screening process, route providers, risk environment or applicable requirements change. The effective date should be updated when a revised policy is published.