AML/KYC Policy

Last updated: February 18, 2026

This policy describes SwapCult's approach to anti-money-laundering (AML), counter-terrorist financing (CTF), sanctions compliance, and know-your-customer (KYC) controls.

Policy Objectives

Our compliance framework is designed to detect, prevent, and report illicit activity, including fraud, money laundering, terrorist financing, sanctions breaches, and other prohibited conduct.

Risk-Based Program

We apply risk-based controls that consider transaction patterns, geography, asset type, behavioral indicators, and other relevant factors. Control intensity may vary depending on the risk profile of a transaction or user.

Customer Due Diligence

We may request identity information at onboarding or during use of the service where required by law, policy, or risk triggers. Additional enhanced due diligence may be requested for higher-risk activity.

Verification and Screening

We may request identity verification or additional information based on transaction risk, regulatory requirements, or suspicious activity indicators. We screen users and counterpart data against applicable sanctions lists, watchlists, and other risk databases.

Source of Funds and Source of Wealth

Where appropriate, we may request supporting documents or explanations to establish the lawful origin of funds or assets involved in transactions.

Transaction Monitoring

We monitor transactional activity using internal controls and external risk signals to identify unusual behavior. Alerts may result in additional review, temporary holds, request for documents, or escalation.

Reporting and Recordkeeping

We maintain records in accordance with applicable legal and regulatory requirements. Where required, we may file reports or share information with competent authorities.

Restrictions and Enforcement

SwapCult may delay, reject, suspend, or terminate transactions or service access if compliance concerns arise, documentation is insufficient, or legal obligations require intervention.

Policy Updates

We may update this AML/KYC Policy periodically to reflect legal, regulatory, and operational changes. Updated versions are published with a revised effective date.

Contact

For AML/KYC inquiries, contact support@swapcult.com.