Anti-Money Laundering Policy

Last updated: June 25, 2026

1. Introduction

ZeroSwap is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML Policy outlines our approach to compliance while maintaining our commitment to user privacy and non-custodial operations.

2. Non-Custodial Nature

ZeroSwap operates as a non-custodial exchange protocol. We do not hold, control, or have access to user funds at any time. All transactions are executed directly on public blockchains through smart contracts. This architecture inherently limits our ability to freeze or seize assets.

3. Risk-Based Approach

We employ a risk-based approach to AML compliance, focusing on:

• Transaction monitoring for suspicious patterns
• Blockchain analytics for identifying high-risk addresses
• Screening against international sanctions lists (OFAC, EU, UN)
• Cooperation with law enforcement upon valid legal requests

4. Prohibited Activities

Users are prohibited from using ZeroSwap for:

• Money laundering or terrorist financing
• Sanctions evasion
• Fraud or proceeds of crime
• Any activity that violates applicable laws

5. Transaction Monitoring

ZeroSwap utilizes automated blockchain analytics tools to monitor transactions for suspicious activity. Transactions involving addresses flagged by major compliance providers may be restricted or reported.

6. Cooperation with Authorities

ZeroSwap will cooperate with law enforcement agencies and regulatory authorities in accordance with applicable laws. We will respond to valid subpoenas, court orders, and other legal processes.

7. Record Keeping

Transaction records visible on public blockchains serve as an immutable audit trail. ZeroSwap maintains internal logs for compliance purposes as required by applicable law.

8. Updates

This policy may be updated from time to time. Changes will be posted on this page.

9. Contact

For compliance inquiries: compliance@zeroswap.club