AML Policy

Effective date: [insert date]

This Anti-Money Laundering (“AML”) Policy describes the principles applied by SwapATOM in connection with anti-money laundering, counter-terrorist financing, sanctions compliance, fraud prevention, and other misuse-prevention obligations.

1. Purpose

SwapATOM is committed to taking reasonable steps to prevent the use of its website or related services for unlawful activity, including:

  • money laundering,
  • terrorist financing,
  • sanctions evasion,
  • fraud,
  • use of stolen funds,
  • cybercrime-related proceeds movement,
  • other prohibited or abusive conduct.

2. Risk-Based Approach

We apply a risk-based approach to compliance. This means the level of review, monitoring, or restrictions may vary depending on factors such as:

  • transaction size,
  • transaction pattern,
  • wallet exposure,
  • blockchain tracing indicators,
  • geographic or sanctions-related risks,
  • technical anomalies,
  • source-of-funds concerns,
  • evidence of suspicious activity.

3. Right to Review Transactions

We reserve the right to review any transaction, request, or user interaction for compliance purposes. This may include manual or automated checks designed to detect:

  • suspicious transaction patterns,
  • high-risk wallet connections,
  • links to darknet markets or illicit services,
  • stolen or mixed funds,
  • sanctions exposure,
  • fraudulent or deceptive behavior.

4. Information Requests

Where necessary, we may request additional information before allowing a transaction to proceed or before resolving a pending issue. Such information may include, where reasonably required:

  • identity information,
  • source-of-funds explanation,
  • source-of-wealth explanation,
  • wallet ownership confirmation,
  • supporting transaction documentation,
  • additional compliance-related clarifications.

Failure to provide requested information may result in delay, refusal, cancellation where technically possible, or other restrictions.

5. Refusal, Suspension, or Blocking

We may refuse, suspend, delay, or block access to a transaction or service if we reasonably believe that:

  • the activity may violate applicable law,
  • the transaction presents AML/CFT risk,
  • sanctions concerns are identified,
  • fraud or unauthorized use is suspected,
  • required verification has not been completed,
  • the user provides false or misleading information,
  • the transaction involves prohibited jurisdictions or restricted parties.

6. Sanctions Compliance

We do not intend to provide services to individuals, entities, wallets, or regions subject to applicable sanctions or restrictions under relevant legal regimes.

We may use screening measures to identify possible sanctions exposure. If a match or elevated risk is identified, we may pause or refuse service and, where required, take additional compliance action.

7. Monitoring and Blockchain Analysis

To help prevent abuse, we may use internal review methods and third-party compliance tools, including blockchain analytics and transaction screening solutions.

These tools may assist in identifying risk indicators connected to:

  • sanctioned wallets,
  • hacked or stolen funds,
  • ransomware proceeds,
  • mixers or obfuscation services,
  • fraudulent schemes,
  • other high-risk transaction sources.

8. Recordkeeping

We may retain transaction-related and compliance-related records for as long as reasonably necessary to:

  • comply with legal obligations,
  • document internal compliance decisions,
  • prevent fraud and repeat abuse,
  • respond to lawful requests,
  • resolve disputes.

9. User Responsibilities

By using this website, you represent and warrant that:

  • your funds are derived from lawful sources,
  • you are acting on your own behalf or with lawful authority,
  • you are not using the service for illegal purposes,
  • you are not subject to applicable sanctions that prohibit use,
  • the information you provide is accurate and not misleading.

10. No Guarantee of Transaction Completion

Submission of a transaction request does not guarantee acceptance or completion. Transactions may be delayed, declined, or subject to additional review for technical, liquidity, compliance, or risk reasons.

11. Cooperation With Authorities

Where required by applicable law, lawful request, court order, regulatory obligation, or enforcement process, we may cooperate with competent authorities and provide information relevant to an investigation or compliance requirement.

12. Policy Updates

We may amend this AML Policy at any time to reflect legal, regulatory, operational, or risk-management changes. The latest version will be published on this page with an updated effective date.

13. Contact

For AML or compliance-related inquiries, contact:

Email: [email protected]
Website: swapatom.com