Anti-Money Laundering and Financial Crime Statement
Last updated: 2026-10-03 Version: 1.2 Status: Advance notice Effective: New products and features: first use on or after 7 October 2026; existing services: 10 November 2026, subject to the notice period below
For newly available products and features, this edition applies when you first choose to use the relevant service and accept its terms, on or after 7 October 2026. The product must actually be launched and available to you. For changes to services you already use, this edition applies from 10 November 2026, but never earlier than 30 days after we notify you of the changes, or a later date required by applicable law. Until then, the previous conditions continue for those existing services. Accepting in advance does not shorten that transition. Publication and acceptance do not make a product available or establish regulatory permission.
Supa Labs OÜ, registry code 17399414, prohibits use of Swaps for money laundering, terrorist financing, fraud, sanctions evasion and handling criminal proceeds. This statement explains our approach; it is not a licence, regulatory opinion or certification that any transaction is compliant. Contact: legal@swaps.app.
1. Responsibilities depend on the service
Swaps provides the software and integration functions described in the Terms. Our obligations depend on what we actually do and the laws applicable to that activity. We do not claim exemption from financial-crime obligations simply because software is non-custodial or a provider performs part of a transaction.
A provider may independently perform customer and business verification, beneficial-owner checks, screening, monitoring, information collection, reporting and record keeping under its own obligations. Those duties are not automatically transferred to Swaps, and the provider's authorisation does not authorise Swaps to conduct a regulated activity.
Wallet-only or crypto-only access may have different verification requirements from a bank or provider route. A feature requiring no identity check at a particular stage is not anonymous, exempt from law, or guaranteed to remain available without further information.
2. Controls and information
Depending on the product and available controls, Swaps can check account and country eligibility, provider readiness, credentials and transaction limits, screen blockchain risk signals, and review unusual activity. We can request an explanation, source-of-funds information, business details, invoice or recipient evidence when necessary for the service, investigation or an applicable obligation.
Information may be passed to the relevant provider through an onboarding or compliance process. A provider may require more information directly. Use designated channels, provide truthful information and do not submit another person's identity or documents without authority.
Automated screening can produce false positives or miss relevant risks. A completed check is not a guarantee that a person, address or transaction is lawful. Our address intelligence is not a substitute for a user's own required compliance programme.
3. Restrictions and cooperation
We may delay or decline an instruction, restrict a route or suspend access where reasonably necessary for risk, provider or legal requirements. A provider can independently take its own action. An interface restriction does not necessarily freeze an on-chain wallet or undo an existing transaction.
Where law requires reporting or disclosure, we comply with the applicable obligation. We may be unable to reveal some information or the existence of a report where disclosure is restricted. This statement does not claim that every report is made to the same authority or that Swaps has a particular regulated status.
We protect and retain records on the basis described in the Privacy Policy. We do not apply an indefinite blanket retention period to all users merely by calling data "AML records".
4. User obligations
Do not disguise transaction purpose, ownership, counterparties or source of funds. Do not split payments to avoid limits, use third-party accounts outside permitted routes, or provide misleading beneficial-owner information. The AUP, Sanctions Policy and applicable provider rules govern permitted use.
5. Questions and review
Contact legal@swaps.app about a restriction or to correct information. We will review what can lawfully be reviewed and identify the relevant provider process where appropriate. See Limits and Enforcement. A review request does not guarantee reinstatement or a particular provider outcome.