The cryptocurrency exchange Swaply AML Policy is created to prevent money laundering and counter terrorist financing in line with the European AML/CTF legislation and obligations arising from it including the need to have adequate systems and controls in place to mitigate the risk of cryptocurrencies being used to facilitate financial crime.
Money Laundering
- means the following conduct, when committed intentionally,
- the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;
- the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
- the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;
- participation in, association to commit, attempts to commit and aiding.
Terrorist financing
provides funds for terrorist activity. It may involve funds raised from legitimate sources, such as personal donations and profits from businesses and charitable organizations, as well as from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion.
AML Policy and KYC Routines include:
identifying the Client and verifying the Client's identity on the basis of documents, data or information obtained from a reliable and independent source;
identifying the beneficial owner and taking reasonable measures to verify that person's identity so that the obliged entity is satisfied that it knows who the beneficial owner is, including, as regards legal persons, trusts, companies, foundations and similar legal arrangements, taking reasonable measures to understand the ownership and control structure of the Client;
assessing and, as appropriate, obtaining information on the purpose and intended nature of the business relationship;
conducting ongoing monitoring of the business relationship including scrutiny of transactions undertaken throughout the course of that relationship via Coinfirm’s C-Score to ensure that the transactions being conducted are consistent with the obliged entity's knowledge of the customer, the business and risk profile, including where necessary the source of funds and ensuring that the documents, data or information held are kept up-to-date.
conduct employees trainings in the field of money laundering and terrorism financing issues knowledge,
Sanctions Policy
Swaply is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists.
Video verification
We kindly inform you that the video verification is carried out in relation to the following group of clients:
- an e-resident;
- a person from a country outside the European Economic Area or whose place of residence or seat is in such country;
- a natural person from an EEA country whose total sum of transactions exceeds 15,000 euros per calendar month; or
- a legal person from an EEA country whose total sum of transactions exceeds 25,000 euros per calendar month.
It must be noted that the video identification of a person and verification of person's identity does not oblige the Service Provider to establish a business relationship or guarantee the accessibility of services.
Additionally, it is stated that the video verification is not successful when:
- The Client has not confirmed that he has read the information about the use of information technology,
- The Client has not agreed to the conditions of identification of a person and verification of person’s identity with information technology means.
- The Client has submitted different data than in the identity documents,
- The Client has not performed any activity within 15 minutes of the video verification.
- The Client is suspected for money laundering or terrorist financing.