Privacy PolicyTerms of ServiceAML/KYC Policy

AML/KYC Policy

Introduction

Money laundering is the attempt to conceal or disguise the nature, location, source, ownership, or control of illegally obtained money. Money laundering is often associated with tax avoidance. However, other individuals may attempt to launder money to conceal their identity or finance their operations.

"Suspicious activity" is a difficult concept to define because it can vary from one transaction to another based on all the circumstances surrounding the transaction or group of transactions. For example, transactions by one customer may be normal based on our knowledge of that customer and their pattern of activity, while similar transactions by another customer may be suspicious. Many factors are involved in determining whether transactions are suspicious, including the amount, nature of the transaction, and frequency of deposits and withdrawals from the system.

SWIFTFIAT LTD is committed to combating money laundering and fully complying with all applicable anti-money laundering laws and regulations. We recognize our responsibility in supporting the global fight against money laundering, terrorist financing, fraud, and other financial crimes. This commitment supersedes all other privacy obligations contained within our policies.

Accordingly, SWIFTFIAT LTD will take all reasonable and appropriate measures to prevent individuals or entities engaged in money laundering, fraud, terrorist financing, or other financial crimes from utilizing our products and services. Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable laws and regulations and shall be reviewed and updated periodically to reflect regulatory developments and changes in our business operations.

The key components of our Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) framework include the following:

Compliance Officer

SWIFTFIAT LTD shall appoint a Compliance Officer who shall be responsible for:

  • Coordinating and monitoring day-to-day compliance with relevant legislation, regulations, rules, industry guidance, and applicable AML/CFT laws.
  • Monitoring transactions to detect unusual, suspicious, or potentially illicit activities.
  • Ensuring the prompt preparation and submission of all required regulatory reports and returns.
  • Communicating AML/CFT matters and compliance requirements to relevant stakeholders.
  • Ensuring that our AML/CFT policies and procedures are effectively implemented and maintained.

Risk Committee

We shall maintain an independent Risk Committee that reports regularly to the Board of Directors on all risk and compliance matters. The Risk Committee shall:

  • Adopt a risk-based approach to the assessment and management of money laundering and terrorist financing risks.
  • Ensure compliance with applicable AML/CFT legislation, regulations, and regulatory requirements.
  • Formulate, implement, and monitor internal controls designed to deter criminals from using our facilities for money laundering or terrorist financing.
  • Ensure that we fulfill all obligations imposed by applicable laws, regulations, and regulatory authorities.
  • Review emerging risks and recommend appropriate mitigation measures.

Know Your Customer (KYC)

SWIFTFIAT LTD shall establish and maintain a risk-based Customer Due Diligence (CDD) program, including customer identification, verification, and Know Your Customer (KYC) procedures. To meet these standards, customers are required to provide specified personal information when opening an account. Customers are also required to utilize security measures such as One-Time Passwords (OTP), authentication tokens, and Personal Identification Numbers (PINs) when initiating withdrawal requests.

The nature and extent of customer verification requirements shall be determined based on factors including:

  • Deposit and withdrawal limits.
  • Account type and intended use.
  • Geographic location and country of residence.
  • Risk profile of the customer.

Where higher-risk customers are identified, including customers conducting large-volume transactions, we may apply Enhanced Due Diligence (EDD) measures as deemed necessary. We shall maintain all KYC and CDD records for the minimum period prescribed by applicable laws and regulations and shall ensure the timely and accurate submission of all AML/CFT reports and returns required by regulatory authorities.

Suspicious Transaction Monitoring and Reporting

SWIFTFIAT LTD shall exercise due diligence in identifying, investigating, and reporting suspicious transactions where appropriate. Suspicious transactions may include, but are not limited to:

  • Transactions structured to avoid reporting or record-keeping requirements.
  • Transactions involving altered, forged, false, or inconsistent identification documents or information.
  • Transactions that, in our reasonable opinion, may be linked to criminal activity.
  • Transactions involving persons, organizations, or entities known or suspected to be associated with terrorism or terrorist financing.
  • Any activity that appears unusual, lacks an apparent lawful purpose, or is inconsistent with the customer's known profile and transaction history.

All identified suspicious activities shall be escalated and handled in accordance with applicable AML/CFT laws and reporting obligations.

Employee Training and Awareness

SWIFTFIAT LTD shall provide ongoing AML/CFT training and awareness programs to all relevant employees and personnel. Such training shall ensure that employees:

  • Understand applicable AML/CFT laws, regulations, and obligations.
  • Can identify and report suspicious activities.
  • Understand internal AML/CFT policies and procedures.
  • Remain informed of emerging money laundering and terrorist financing risks.

Settlement and Account Verification

To strengthen fraud prevention and AML controls, we shall only remit settlement proceeds to verified bank accounts that have been duly registered and validated on our platform. No withdrawals or settlements shall be processed to unverified third-party accounts.

Policy Review

This AML Policy shall be reviewed periodically and updated as necessary to reflect changes in applicable laws, regulations, industry standards, and business operations. SWIFTFIAT LTD remains committed to maintaining a robust and effective AML/CFT framework to protect its platform, customers, and the wider financial system from abuse.

Contact Information

Questions relating to AML/KYC matters may be directed to support@swiftfiat.com, subject to the limits of information we can disclose during an active compliance review or investigation.