Anti‑Money Laundering Policy

Anti‑Money Laundering Policy (AML). The SWT service warns users against attempting to use the service for money laundering, financing of terrorism, any unlawful activity of any kind, as well as for purchasing prohibited goods and services. Money laundering is the concealment of the illicit origin of funds by converting them into money or investments that appear lawful.

General provisions
To prevent unlawful operations, the Service sets certain requirements for all Orders created by a User:

• 1. The sender and the recipient of the Payment under an Order must be the same person. Transfers in favor of third parties using the Service are prohibited.
• 2. All contact details entered by the User in the Order, as well as other personal data provided by the User to the Service, must be current and entirely accurate.
• 3. It is prohibited for a User to create Orders using anonymous proxy servers or any other anonymous connections to the Internet.

This Anti‑Money Laundering Policy (hereinafter — "AML Policy") describes the procedures and mechanisms used by the E‑Change Service to counter money laundering. The E‑Change Service adheres to the following rules:

• 1. not to enter into business relationships with persons known to be criminals and/or terrorists;
• 2. not to process transactions that are the result of known criminal and/or terrorist activity;
• 3. not to facilitate any deals connected with known criminal and/or terrorist activity;
• 4. to have the right to limit or prohibit the use of all or part of the services for citizens of such countries as Afghanistan, Bosnia and Herzegovina, USA, Democratic People’s Republic of Korea, Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, Lao People’s Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine;
• 5. verification procedures.

The SWT Service establishes its own verification procedures within AML standards — the "Know Your Customer" (KYC) policy:

• 1. Users of the SWT Service undergo verification (provide a government ID document: passport or ID card). The SWT Service reserves the right to collect Users’ identification information for the purposes of implementing the AML Policy.
• 2. The SWT Service may also request a second document to identify the User: a bank statement or utility bill not older than 3 months showing the User’s full name and actual place of residence; the service is also entitled to request photo/video verification of the client if there are suspicions about the integrity of the information provided.
• 3. The SWT Service verifies the authenticity of documents and information provided by Users and reserves the right to obtain additional information about Users who are identified as risky or suspicious.

If a User’s identification information has changed or their activity appears suspicious, the SWT Service has the right to request updated documents, even if they have previously passed authenticity checks.

AML Compliance Officer
The AML Compliance Officer is an SWT employee responsible for ensuring compliance with the AML Policy, namely:

• 1. creating and updating internal policies and procedures for drafting, reviewing, submitting, and storing all reports required under applicable laws and regulations;
• 2. monitoring transactions and analyzing any significant deviations from Users’ normal activity;
• 3. regularly updating risk assessments.

The AML Compliance Officer is authorized to liaise with law‑enforcement authorities engaged in preventing money laundering, terrorist financing, and other illegal activity.

Transaction monitoring
Monitoring of a User’s transactions and analysis of the data obtained is also a tool for risk assessment and for detecting suspicious operations. If money laundering is suspected, the SWT Service monitors all transactions and reserves the right to:

• 1. report suspicious operations to the relevant law‑enforcement authorities;
• 2. request any additional information and documents from the User;
• 3. suspend or terminate the User’s account;
• 4. suspend an exchange and freeze assets pending clarification of the circumstances;

The above list is not exhaustive. The AML Compliance Officer monitors Users’ transactions daily to determine whether they should be reported and treated as suspicious.

In accordance with international requirements, the SWT Service applies a risk‑based approach to combat money laundering and terrorist financing. Accordingly, the measures to prevent money laundering and terrorist financing are commensurate with the identified risks.