The Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML/KYC Policy”) is designed to prevent and reduce the possible risks of SwapHub being involved in any illegal activities.
SwapHub is owned by Smart Tech Support Limited, registration number: 94021, address: Intershore Suite, Le Sanalele Complex, PO Box 608, Apia, Samoa.
The SwapHub platform adheres to practices and measures in the field of Anti-Money Laundering (AML) and Countering the Financing of Terrorism. The purpose of these measures is to demonstrate that SwapHub takes any attempts to use its service for illegal purposes very seriously.
The SwapHub platform warns users against attempting to use SwapHub for money laundering, terrorist financing, any kind of fraud, or for purchasing prohibited goods and services. SwapHub, its administration, employees, and domain owners bear no responsibility for any unlawful use of the platform by third parties, the actions of malicious actors, or any potential damage related to the use of SwapHub.
To prevent unlawful transactions, the SwapHub platform establishes certain requirements for all Orders created by the User:
4.1. The sender and the recipient of the payment in the Order must be the same person. Transfers in favor of third parties are strictly prohibited when using the Platform’s services.
4.2. All contact details entered by the User in the Order, as well as any other personal data provided by the User to the Platform, must be current and completely accurate.
4.3. The creation of Orders using anonymous proxy servers, VPN, Tor, or any other anonymous internet connections is strictly prohibited.
One of the international standards for preventing illegal activities is proper customer due diligence (hereinafter referred to as Verification). For this purpose, SwapHub implements its own verification procedures in strict compliance with Anti-Money Laundering standards and the Know Your Customer procedure.
5.1. The SwapHub Service may require the User to provide SwapHub with reliable, independent source documents, data, or information to complete verification and confirm the sources of funds. The requested information may include:
- A photograph holding an unfolded passport clearly showing the photo and full name;
- A scan or photograph of the passport (first page, second page, and the page with the residence registration, in good quality);
- Proof of source of funds (photos, screenshots, statements);
- A video showing the person who sent the funds, holding their unfolded passport (clearly showing the photo and full name), stating: "I have created exchange order ID (order number) on SwapHub, the funds sent are my personal funds, and I take full legal responsibility for this cryptocurrency," as well as mentioning the source of funds in the video;
- A recording of a video taken from the platform where the funds were sent from, clearly showing the transaction hash, sender and recipient addresses, the amount with ticker, and the transaction date. The video must be at least 10 seconds long.
5.2. In case of account freezes due to high risk or official investigation, the funds will be held until verification is completed or the investigation ends. For such purposes, SwapHub reserves the right to collect the User’s identification information to comply with the AML/KYC Policy.
5.3. SwapHub will take steps to verify the authenticity of the documents and information provided by Users. All legal means will be used to double-check identification data, and SwapHub reserves the right to investigate cases where certain Users have been identified as high risk or suspicious.
5.4. SwapHub reserves the right to verify a User’s identity on an ongoing basis, especially when their identification information has changed or their activity appears suspicious (unusual for that specific User). Additionally, SwapHub reserves the right to request up-to-date documents from Users even if they have passed verification previously.
5.5. User identification information will be collected, stored, shared, and protected strictly in accordance with the SwapHub Platform’s Privacy Policy and applicable regulations.
5.6. After verifying a User’s identity, SwapHub may refuse to provide services to the User if the services of SwapHub are being used for illegal activities.
5.7. SwapHub has regulatory obligations to verify the source of funds or cryptocurrency to ensure that the sources of funds used by Users for trading are legitimate.
The person responsible for ensuring compliance with AML regulations is an individual duly authorized by the SwapHub Platform, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy.
6.1. The duties of such an officer include overseeing all aspects of SwapHub’s activities related to anti-money laundering, including money laundering and terrorist financing, including but not limited to the following methods:
- Collecting users’ identification information;
- Developing and updating internal policies and procedures for completing, reviewing, submitting, and retaining all reports and records required under applicable laws and regulations;
- Monitoring transactions and investigating any significant deviations from normal activity;
- Implementing a records management system to properly store and retrieve documents, files, forms, and logs;
- Regularly updating risk assessments;
- Providing law enforcement authorities with information required under applicable laws and regulations.
6.2. The officer responsible for AML compliance has the right to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.
The SwapHub platform performs numerous compliance-related tasks, including data collection, filtering, record-keeping, investigation management, and reporting. System functions include:
- Daily screening of Users against recognized “blacklists” (e.g., OFAC), aggregating transfers across multiple data points, placing Users on watchlists and denial lists, opening cases for investigation where necessary, sending internal notifications, and completing mandatory reports where applicable;
- Case and document management.
The SwapHub platform verifies Users not only by confirming their identity but, more importantly, by analyzing their transactional behavior. Therefore, SwapHub relies on data analysis as a tool for risk assessment and suspicion detection.
In accordance with international requirements, SwapHub applies risk assessment practices to combat money laundering and terrorist financing. By applying risk assessment practices, SwapHub ensures that the measures taken to prevent or mitigate money laundering and terrorist financing are proportionate to the identified risks.
If the SwapHub Platform administration has reasonable suspicion that a user is attempting to use the Service for money laundering or for conducting any other illegal activities, the administration has the right to:
- Suspend the execution of the user’s exchange transaction;
- Request identity verification documents from the User;
- Request any additional information and documents from the User in the event of suspicious transactions;
- Ensure that reports about the suspicious nature of transactions are submitted to the appropriate law enforcement authorities through the designated AML compliance officer.
The SwapHub Platform guarantees client confidentiality in accordance with the platform’s Privacy Policy.
11.1. The SwapHub Platform and its employees undertake to maintain confidentiality regarding any facts discovered in connection with any suspicious transaction. This obligation also applies to the Platform’s users and any third parties to whom information about the transaction was disclosed.
11.2. The obligation of SwapHub employees to maintain confidentiality remains in force after the termination of their employment or any other contractual relationships with SwapHub, as well as upon transfer to another position. Disclosure of such information to state or law enforcement authorities and other entities in cases prescribed by law does not constitute a breach of confidentiality obligations.
11.3. The obligation to maintain confidentiality, provided that the use of disclosed information is limited to the prevention of money laundering and terrorist financing, does not apply to information sharing between financial institutions forming a consolidated group that cooperates with the SwapHub Platform.
In view of the foregoing, the SwapHub Platform bears no legal liability for its use in money laundering, terrorist financing, or the purchase of prohibited goods and services, but undertakes to take all possible and available measures to prevent attempts to use the SwapHub Platform for such purposes. By completing an exchange, the User, in accordance with the rules in effect on SwapHub, agrees to all the terms of these policies and undertakes to comply with them.