letsexchange
ToS

Instant swap service, with no mandatory account registration. Fixed and floating rates.

KYC LEVEL 2

The exchange may request KYC from any user at any time, typically triggered by an automated flag system, leading to a temporary block of funds.

May require KYC/SOF by policy/law May block 'suspicious' transactions No registration needed Refunds do not require KYC Non-custodial wallet API available Source code is private
(updated 16 hours ago)
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Automated, ai-driven monthly ToS reviews.

Last Check: 2024-02-16

Transaction Monitoring

According to the AML/KYC Policy, the service uses data analysis to assess risks and detect suspicions in transactional patterns. This includes daily checks against black lists, aggregating transfers, and potentially reporting suspicious transactions to law enforcement. Compliance-related tasks also involve record-keeping and investigation management.

ToS section: "2. MONITORING TRANSACTIONS"

User Identification

The service requires users to verify their identities as part of its Customer Due Diligence process. This includes providing personal identification information and documents such as national ID, passport, bank statement, and documentation for legal entities. Continuous verification may occur, especially if user information changes or activity is deemed suspicious.

ToS section: "1. IDENTIFICATION AND VERIFICATION PROCEDURES"

3rd Party Data Sharing

The AML/KYC Policy allows the service to share user data with law enforcement and regulatory agencies as required by law. Additionally, user identification information is collected in accordance with the service's Privacy Policy, which might involve third-party sharing consistent with legal and regulatory requirements.

ToS section: "1. IDENTIFICATION AND VERIFICATION PROCEDURES"

Data sharing with authorities

The service may share user information with authorities, as the AML/KYC Policy explicitly states that transactions of suspicious nature are reported to the proper law enforcement. The Compliance Officer has the responsibility to provide law enforcement with necessary information under applicable laws and regulations.

ToS section: "2. MONITORING TRANSACTIONS & 4. COMPLIANCE OFFICER"

Logging

The service is likely to log user data, including IP addresses and transactions, as part of its compliance-related tasks described in the AML/KYC Policy. These tasks involve capturing data, filtering, record-keeping, and managing documents, which includes transactions monitoring and possibly IP address logging for security and verification purposes.

ToS section: "2. MONITORING TRANSACTIONS"

Blocking of funds

The service reserves the right to suspend or terminate a user's account if there is reasonable suspicion of illegal activity. In the event of account suspension or termination due to suspicious transactions, it is implied that the service may block or freeze user funds.

ToS section: "2. MONITORING TRANSACTIONS"

Account termination/blocking

User accounts may be suspended or terminated in cases of suspicious transactions or illegal activity. If the KYC/AML procedure fails, for example, if a user refuses to disclose their identity, the service will refund the deposited funds and may blacklist the user's address.

ToS section: "1. IDENTIFICATION AND VERIFICATION PROCEDURES & 2. MONITORING TRANSACTIONS"

Transaction flagging

The service implements a system for monitoring and flagging suspicious transactions. This is part of the compliance officer's duties and the broader data analysis and risk assessment tools being used by the service to detect and report suspicious activities.

ToS section: "2. MONITORING TRANSACTIONS & 4. COMPLIANCE OFFICER"

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