Sanctions and Restricted Jurisdictions
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, restricts use of Swaps as required by applicable sanctions law and by its own service and provider policies. Legal restrictions and commercial country restrictions are different. Contact: legal@swaps.app.
1. Applicable restrictions
Do not use the Service for a transaction prohibited by sanctions applicable to you, Swaps or the participating provider. Depending on the circumstances these can include EU, Estonian, UK, US or other applicable measures concerning designated persons, owned or controlled entities, sectors, assets, services or territories.
Sanctions differ by jurisdiction and change over time. A country restriction does not mean every national of that country is sanctioned, and an address match is not by itself a complete legal assessment. Licences, exemptions and ownership/control rules must be assessed under the applicable regime; our interface does not grant a legal permission.
2. Swaps country policy
At this version, Swaps restricts supported transaction access involving Belarus, Cuba, Iran, North Korea, Russia and Syria under its country policy. This list combines legal, provider and company risk restrictions; it is not a statement that every country is subject to identical or comprehensive sanctions.
Transactions involving a restricted territory, designated person or otherwise prohibited activity can be unavailable even if the country is not in that list. Providers can impose further country, residency, nationality, establishment, beneficiary, asset and rail restrictions. A country shown in an informational list does not guarantee a transaction is available.
Do not use VPNs, nominee accounts, false residence details or indirect routing to evade a restriction. Legitimate travel or shared network infrastructure can produce incorrect location signals; contact us if a restriction appears wrong.
3. Screening and its limits
Swaps and participating providers may assess location, account and business details, transaction patterns and address risk. Provider verification and Swaps controls are distinct. Risk tools and public sanctions data can be incomplete, delayed or incorrect. A "no match" result is not legal clearance, and a risk score does not establish criminal conduct.
Checks can prevent a request or trigger more information. They do not give Swaps universal power to freeze or recover blockchain assets. Providers may have separate blocking, rejection, reporting or retention obligations.
4. Existing transactions and return requests
A new restriction can affect a pending instruction or proposed return. We will handle it under the relevant law, provider arrangement and product terms. A restriction does not automatically transfer ownership of funds to Swaps.
Do not supply an alternative address simply to bypass screening. Return instructions need the verification appropriate to the route; a blockchain sending address may belong to an exchange, intermediary or cross-network solver rather than the payer.
5. Review and changes
Send a correction or restriction-review request to legal@swaps.app. We may request proportionate evidence and may be unable to disclose details protected by law. Provider decisions may require the provider's own appeal process.
We may update access promptly when law, provider requirements or a material risk changes, with notice where required and lawful. The Terms, AUP, AML Statement and Privacy Policy explain related rights and responsibilities.