AML policy

1. Swapftm Policy on Combating Money Laundering, Countering Financing of Terrorism (hereinafter AML Policy), and "Know Your Customer" Policy (hereinafter "KYC Policy") is designed to prevent and reduce potential risks of Swapftm's involvement in any illegal activities. International laws and regulators, as well as the Fifth Directive on Combating Money Laundering and Terrorism Financing (5AMLD), require Swapftm to implement effective internal procedures and mechanisms to prevent money laundering, terrorism financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. Additionally, it mandates taking measures in case of any suspicious actions and activities by its Users. As a virtual/crypto asset service provider, the exchange is obliged to verify all suspicious transactions of virtual/crypto assets. During the verification process, among other things, user identification (KYC) and the origin of the virtual/crypto asset must be established. Also, during the verification period, the virtual/crypto asset must remain on the balance.
   1. By placing an order on the website, the Client agrees that AML/KYC verification may be conducted concerning them.
   2. The AML/KYC verification procedure for clients and transactions is carried out by the AML officer of Swapftm, as well as our liquidity provider, namely a cryptocurrency exchange.
   3. As part of the AML/KYC verification, the Client consents to the processing and storage of their personal data and, if necessary, the transfer of this data to the liquidity provider, namely the AML officer of the cryptocurrency exchange.

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

      • Continuous monitoring of transactions passing through Swapftm
      • Appointment of a responsible person (Money Laundering Reporting Officer)
      • Risk-oriented approach
      • Proper customer verification
      • Enhancement of professional skills and knowledge of Swapftm staff
      • Interaction with government authorities in cases established by law
      • Accounting, record keeping, document management

2. If, as a result of the analysis of AML cryptocurrency assets, a risk above 40% is identified, or any of the following labels is received:

   • DARK SERVICE (associated with the dark side of the internet)
   • SCAM (fraud)
   • STOLEN (theft or data theft)
   • MIXING (MIXER) (mixing funds to hide their origin)
   • SEXTORTION (extortion based on compromising information)
   • RANSOMWARE (extortion using ransomware)
   • HACK (hacking)
   • PHISHING (phishing)
   • TERRORISM FINANCING (financing terrorism)
   • FRAUD (fraud)
   • BLACKLIST (presence in blacklists)
   • STILL UNDER INVESTIGATION (still under investigation)
   • CYBERCRIME ORGANIZATION (organization associated with cybercrime)
   • NARCOTICS (drugs)
   • CHILD ABUSE (child abuse)
   • HUMAN TRAFFICKING (human trafficking)
   • SANCTIONS (sanctions)

   and other high-risk assets, the Client's transaction may be frozen indefinitely until the completion of identity verification (KYC).

   1. Upon receiving a service request from our liquidity provider, namely a cryptocurrency exchange, the Client's transaction may be frozen indefinitely until the completion of identity verification (KYC).
   2. Upon receiving a request from competent authorities, the Client's transaction may be frozen indefinitely until the completion of identity verification (KYC).
   3. In case of any suspicious activity identified by the AML officer of Swapftm, the Client's transaction may be frozen indefinitely until the completion of identity verification (KYC).

3. Documents required for KYC verification:

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

   • Through which platform did the funds come to you? Please provide screenshots from the wallet/platform withdrawal history, as well as links to both transactions in the explorer.
   • For what service did you receive the funds?
   • What was the transaction amount, date, and time of its completion?
   • Through which contact person did you communicate with the sender of the funds? Please provide screenshots of correspondence with the sender, where we can see confirmation of the funds' sending.

   Also, please provide the following materials:

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

   If necessary, the service is entitled to request additional documents not specified in this section. All submitted images (scans, photos, screenshots) must be in jpeg or png format.

   1. The processing time for documents for KYC verification is individual for each case and is not regulated by time.
   2. Return of blocked assets is possible only after passing KYC verification.
   3. User assets that have not passed AML verification are not subject to exchange.
   4. After a positive KYC verification, the client will be refunded with a deduction of a 5% commission.

   5. Please note that our service reserves the right to charge an additional commission of up to 5 percent for transactions that have signs of high risk, such as:

      • DARK SERVICE (associated with the dark side of the internet)
      • SCAM (fraud)
      • STOLEN (theft or data theft)
      • MIXING (MIXER) (mixing funds to hide their origin)
      • SEXTORTION (extortion based on compromising information)
      • RANSOMWARE (extortion using ransomware)
      • HACK
      • PHISHING
      • TERRORISM FINANCING
      • FRAUD
      • BLACKLIST
      • STILL UNDER INVESTIGATION
      • CYBERCRIME ORGANIZATION
      • DRUGS
      • CHILD ABUSE
      • HUMAN TRAFFICKING
      • SANCTIONS

      This additional commission is applied to compensate for additional analysis and risk reduction measures necessary for processing high-risk transactions.

   6. Asset return is not possible if a request has been received from competent authorities or if there is an arrest/blockage by other authorities of any jurisdiction (in this case, the blocked asset may be treated as tangible evidence).
   7. Your assets will be blocked from next exchanges: Garantex, Tornado Cash, Hydra, Blender.io, Lazarus, Group, Genesis, Market, ChipMixer, Shinbad.io, Commex and also from any Iranian excnahges and any exchanges under sanctions.