Anti-money-laundering policy

Money-laundering controls exist to stop criminal proceeds entering the financial system. The industry’s usual answer is to identify every customer, which collects an enormous amount of personal data about millions of people who have done nothing, and stores it where it can leak.

We take the other route available to a non-custodial exchange: we assess the coins, not the person. A deposit address either has a history that matters or it does not, and that question is answered on-chain, publicly, without anyone handing over a passport. It is not a perfect control. Neither is the other one. It is the one that does not require us to build a database of identities we have no business holding.

• We never hold your funds. Coins move deposit → payout, with no balance in between. There is no account to open, therefore no account to verify.
• Identity data we do not collect cannot leak. Every large identity breach of the last decade was of data collected « for compliance ».
• An identity check would not tell us what matters here. Whether a deposit comes from a sanctioned address is answered by the chain, not by a scan of a driving licence.

So: no document, no selfie, no proof of address, no source-of-funds questionnaire, no account — and no amount at which that starts. It is not a limit we raise for verified users; there are no verified users.

Your swap is settled by a wholesale liquidity desk. Like every regulated counterparty in this market, that desk screens incoming deposits automatically against:

• sanctions lists — addresses designated by the authorities whose rules it operates under;
• known theft and exploit addresses — funds publicly attributed to a hack or a ransom;
• darknet market addresses flagged by chain-analysis providers.

This is an automated check against an address, run on every deposit, by a system that does not know and does not ask who sent it. It is not an investigation, it does not profile you, and passing it is the normal outcome for essentially every ordinary deposit.

If a deposit is flagged by that screening, the exchange stops instead of settling. This is the only circumstance in which a swap on this service is held — not an amount, not a frequency, not a country, not a pattern we did not like.

We are telling you this because the alternative is worse. Plenty of services promise that funds are « never frozen, whatever happens » and then quietly do exactly this, because no counterparty in this market can settle a sanctioned deposit. A promise that breaks on the day it matters is not a feature; it is the moment a user discovers the whole page was marketing.

• You are told. The order page shows the exchange has stopped; it does not sit on « processing » forever.
• Where the law allows a return, the deposit goes back to the refund address on the order, minus the network fee to send it. This is the ordinary outcome of a false positive, which is what most flags are.
• We do not ask you for documents to release funds. We hold none, so we have nothing to release. If the desk cannot lawfully return a deposit, no amount of paperwork sent to us changes that — and we will say so rather than string you along.

Watch for this scam. A common fraud is a message claiming your exchange is blocked pending « verification », asking for ID or an unlock payment. We will never ask you for either. There is no unlock fee, and there is no verification department.

We do not ask where you are, and we do not geolocate you to decide whether to serve you. What we cannot do is settle an exchange that our counterparty is prohibited from settling — a jurisdiction under comprehensive sanctions is a hard stop at the desk, not a preference of ours.

Crypto rules differ sharply from country to country. Whether using this service is lawful where you are is your call to make, and the acceptable-use section of the terms says so plainly.

• Ask for identity documents as a condition of exchanging.
• Introduce a verification threshold above a certain amount.
• Build a customer database, or sell, rent or share one — there is nothing to build it from.
• Hold funds to pressure you into providing information.
• Claim that a swap can never be stopped, which no honest operator in this market can claim.

If any of this ever changes, it changes on this page first, with the date at the top, and not quietly in an email after you have deposited.