AML Policy

Effective Date: 19-04-2025

1. Introduction

Swappbit, operated by TRUSTLUB SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, is committed to preventing any activity related to money laundering and terrorist financing through its platform. We adhere strictly to Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations and work diligently to identify, assess, and mitigate these risks.

2. Purpose

This AML Policy outlines the internal procedures, systems, and controls Swappbit employs to detect, prevent, and report potential money laundering or terrorism financing activities in accordance with applicable regulations.

3. Know Your Customer (KYC)

Swappbit implements a strict Know Your Customer (KYC) policy as part of our AML compliance program. We verify the identity of each customer using reliable, independent documents, data, or information, including:

• Government-issued identification (e.g., passport, national ID card)

• Proof of address (e.g., utility bill, bank statement)

• Selfie verification, SOF/SOW documents if required

4. Customer Due Diligence (CDD)

We perform customer due diligence before establishing a business relationship or processing transactions. Depending on the customer’s profile, we apply:

• Standard Due Diligence: For typical users with no risk indicators.

• Enhanced Due Diligence: For high-risk customers, including those from high-risk jurisdictions, or with suspicious transaction patterns.

5. Ongoing Monitoring

Customer activities are monitored on a continuous basis to detect suspicious transactions or behaviors, including:

• Large or unusual transactions

• Transactions inconsistent with a customer’s known profile

• Multiple small transactions structured to avoid reporting thresholds

Swappbit reserves the right to suspend or terminate accounts involved in suspicious activities.

6. Reporting Suspicious Activity

Any suspicious transaction or activity is documented and may be reported to the relevant regulatory and enforcement authorities in accordance with local laws and guidelines. We cooperate fully with requests from law enforcement agencies and regulators.

7. Record Keeping

Swappbit maintains comprehensive records of customer identification, transactions, and reports for at least 5 years or longer if required by applicable law. These records are kept secure and confidential.

8. Training

All employees and associates involved in compliance and customer operations are provided with ongoing training to recognize and deal with money laundering risks. This includes updated procedures, regulations, and reporting methods.

9. Risk Assessment

Swappbit conducts regular risk assessments of its services, customers, and geographic locations to ensure our AML measures remain effective and current.

10. Sanctions and Watchlists

Swappbit screens customers against relevant sanctions lists, including but not limited to those issued by:

• The United Nations (UN)

• The European Union (EU)

• The Office of Foreign Assets Control (OFAC)

• Other international bodies

We do not conduct business with individuals or entities listed on such watchlists.

11. Policy Updates

This AML Policy may be updated periodically in response to regulatory changes, internal assessments, or operational needs. We encourage users to review the policy regularly.

12. Contact Us

For questions or further information regarding this AML Policy, please contact us at:

TRUSTLUB SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
Email: [email protected]