AML Policy
Last updated: January 2026. Anti-Money Laundering and Counter-Terrorism Financing Policy. Privacy and integrity are not opposites — they are both requirements.
1. Introduction and Scope
Exchs Finance is an anonymous, no-KYC cryptocurrency exchange service. We are committed to ensuring our platform is not used to facilitate money laundering, terrorist financing, sanctions evasion, or other serious financial crimes. While our service is designed to protect the financial privacy of legitimate users, we draw a firm and unambiguous line against facilitating criminal activity of any kind.
This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy sets out the framework we apply to manage financial crime risk. It applies to all users of the Service, all transactions processed through the platform, and all personnel involved in operating the Service.
Privacy is a legitimate human need. Money laundering and terrorism financing are serious crimes. These statements are not in conflict, and this policy reflects that distinction.
2. Strictly Prohibited Activities
The following activities are absolutely prohibited on the Exchs Finance platform. Engaging in any of them constitutes a material breach of our Terms of Use and may result in immediate service refusal and disclosure to law enforcement where legally required:
- Laundering the proceeds of crime, including converting, transferring, or concealing funds derived from any illegal activity
- Financing terrorist organisations, individuals designated as terrorists, or any activity connected to political violence
- Circumventing or evading economic sanctions imposed by the United Nations, European Union, United States OFAC, or any other applicable international or national authority
- Processing funds derived from fraud, theft, extortion, ransomware, or any other predicate offence
- Processing proceeds from darknet market transactions, human trafficking, narcotics distribution, or other serious organised crime
- Deliberate tax evasion in violation of applicable law
- Structuring transactions to avoid reporting thresholds or detection
3. Transaction Limits as a Risk Control
Exchs Finance imposes per-transaction limits as part of our risk management framework:
- Minimum transaction value: Equivalent to $100 USD
- Maximum transaction value: Equivalent to $282,100 USD
These limits are applied to all users equally, without exception. They serve to limit our exposure to high-volume financial crime while preserving accessibility for the legitimate users our service is designed for. The exact cryptocurrency equivalent of these limits is displayed in the exchange widget before any order is created.
4. Our Risk-Based Controls
While we operate without collecting user identity data, we apply a meaningful risk-based approach to AML/CTF compliance through the following technical and operational measures:
- Automated transaction monitoring: Our systems monitor for unusual transaction patterns, rapid sequential orders, and other behavioural signals associated with financial crime.
- Transaction velocity limits: Technical controls limit the rate at which orders can be created to prevent structuring or layering behaviour.
- Blockchain address screening: We reserve the right to employ blockchain analytics tools to screen deposit and destination addresses against known databases of high-risk addresses associated with sanctions, darknet markets, ransomware wallets, and other criminal activity. We may refuse service where screening indicates elevated risk.
- Discretionary service refusal: We reserve the unconditional right to refuse service to any transaction or user at our sole discretion, without providing a reason and without liability for the refusal.
5. User Declarations
By using Exchs Finance, every user confirms, represents, and warrants each of the following at the time of every transaction:
- The funds being exchanged are legally obtained and are not, in whole or in part, the proceeds of any criminal activity.
- You are not subject to sanctions designations by the United Nations, the European Union, OFAC, or any other applicable authority.
- Your use of the Service does not violate any AML, CTF, or sanctions law applicable in your jurisdiction.
- You will not use the Service as a conduit to assist any third party in violating AML or CTF regulations.
- You are not acting as an agent, nominee, or intermediary for an undisclosed third party whose use would otherwise be prohibited.
6. Cooperation with Law Enforcement
Exchs Finance will cooperate fully with legitimate law enforcement and regulatory authorities where we are legally required to do so. Where a valid legal order, subpoena, warrant, or other compulsory legal process is served on us, we will provide whatever information we lawfully hold relevant to that order.
We note that by design, the information we retain about any given transaction is technically minimal: deposit address, destination wallet, currency pair, amount, and timestamp — held in session storage without persistent user identity linkage. This structural limitation on data retention is not intended to obstruct lawful investigations; it reflects our privacy-first architecture.
We encourage any user who suspects money laundering or terrorist financing activity connected to cryptocurrency transactions to report it to their national financial intelligence unit (FIU) or relevant law enforcement agency.
7. No Protection from Liability
Use of Exchs Finance's anonymous, no-KYC service does not provide any shield from criminal liability. A user who employs our platform for money laundering, terrorist financing, sanctions evasion, or any other financial crime remains fully and personally liable under the laws of their jurisdiction. The absence of identity collection on our part does not create legal anonymity in any meaningful sense where serious criminal offences are involved.
8. Staff and Operational Responsibilities
All individuals involved in operating or administering the Exchs Finance platform are required to be aware of and comply with this AML Policy. Any suspicious activity identified in the course of platform operations will be escalated and handled in accordance with applicable legal obligations.
9. Policy Review and Updates
This AML Policy is reviewed periodically and updated to reflect changes in applicable law, evolving financial crime typologies, and the operational environment of the Service. All updates will be published on this page with a revised effective date.
10. Contact
For AML-related inquiries, to report suspicious activity observed in connection with our platform, or for compliance-related correspondence, please contact us at support@exchs.finance.