AML / KYC Policy

1. Our Approach

c2swap is a non-custodial cryptocurrency exchange interface. We do not take custody of user funds at any point, and accordingly we operate a minimal-touch AML/KYC model consistent with our non-custodial status. Our Exchange Partners, however, are regulated financial services entities that maintain their own comprehensive AML and KYC programmes in accordance with applicable law.

2. No Custody — No Direct AML/KYC Obligation

Because c2swap never holds, transmits, or controls user funds, we do not act as a money services business (MSB), virtual asset service provider (VASP), or equivalent regulated entity in most jurisdictions. We do not collect government-issued identification, perform identity verification, or conduct transaction monitoring on user funds. These obligations are borne by our Exchange Partners, who are subject to applicable financial regulations in their jurisdictions.

3. Exchange Partner KYC

All swaps facilitated through c2swap are executed by licensed Exchange Partners who operate under regulatory frameworks that include AML and KYC requirements. Exchange Partners may, at their discretion:

• Require identity verification for transactions above certain thresholds imposed by their regulators;
• Screen wallet addresses against sanctions lists and blockchain analytics tools;
• Delay, refuse, or reverse a swap if a transaction is flagged as potentially suspicious;
• Report transactions to competent authorities as required by law.

By using the Service, you acknowledge and agree to comply with any KYC or identity verification requirements imposed by the applicable Exchange Partner.

4. Sanctions and Prohibited Jurisdictions

The Service is not available to individuals or entities that are:

• Located in, or residents of, jurisdictions subject to comprehensive sanctions programmes (including but not limited to OFAC, EU, and UN sanctions lists);
• Designated on any sanctions list as a Specially Designated National (SDN), blocked person, or equivalent;
• Attempting to use the Service on behalf of any of the above.

We reserve the right to refuse service and to block access from sanctioned jurisdictions without prior notice.

5. Prohibited Activities

The Service must not be used in connection with any illegal activity, including but not limited to:

• Money laundering or proceeds-of-crime offences;
• Terrorist financing or the financing of proliferation of weapons;
• Tax evasion or fraud;
• Ransomware payments or facilitating cybercrime;
• Any other activity prohibited under applicable law in your jurisdiction or ours.

6. Our Compliance Measures

Although we do not conduct KYC on users, we implement the following measures consistent with our non-custodial model:

• We work exclusively with Exchange Partners who are licensed or regulated in their respective jurisdictions and maintain their own AML/KYC programmes;
• We implement IP-based rate limiting to detect and mitigate automated abuse of the Service;
• We reserve the right to suspend or terminate access to the Service for any user we reasonably believe is engaged in prohibited activity;
• We cooperate fully with law enforcement and regulatory bodies to the extent required by applicable law.

7. Reporting Suspicious Activity

If you become aware of suspicious activity conducted through the Service, or if you believe your swap is being used in connection with a crime, please contact us immediately at support@c2swap.com. We take all such reports seriously and will investigate and refer them to the appropriate authorities where required.

8. Updates to This Policy

We may update this AML/KYC Policy from time to time to reflect changes in applicable law, regulatory guidance, or our business practices. We will indicate the date of the most recent revision at the top of this page. Continued use of the Service constitutes acceptance of the revised policy.

9. Contact

For compliance-related enquiries, please contact us at support@c2swap.com.