Anti-Financial Crime Policy
Last updated: January 2026. Stellar Swap is an anonymous XLM swap platform that processes cryptocurrency exchanges — including Stellar Lumens, Bitcoin, Monero, USDT, Ethereum, XRP and 60+ other assets — without collecting user identity. This policy explains how we prevent financial crime while keeping confirmed orders free of AML holds and document requests.
1. Our Position on Privacy and Compliance
Stellar Swap was built on a clear distinction: protecting legitimate users from unnecessary surveillance is not the same as enabling criminal activity. We do not require identity verification to swap any supported cryptocurrency pair. We do, however, maintain firm automated controls to prevent the platform from being used for money laundering, financing violence or processing funds derived from illegal activity.
Our model demonstrates that an anonymous, no-registration Stellar XLM swap exchange can operate responsibly. Effective risk management does not require knowing who you are — it requires evaluating the risk profile of the transaction itself. That evaluation happens automatically before any swap is accepted, not after your funds are already inside the system.
2. Prohibited Activities
The following uses of Stellar Swap are strictly prohibited regardless of the asset pair selected:
- Processing funds derived from fraud, theft, extortion or other criminal offenses.
- Financing terrorism, political violence or any sanctioned militant organization.
- Circumventing economic sanctions imposed by the United Nations, European Union, OFAC or equivalent bodies.
- Liquidating proceeds from ransomware attacks, darknet drug distribution or human trafficking.
- Executing structured micro-transactions designed to probe or evade our automated risk thresholds.
3. Transaction Limits as a Risk Control
Rather than demanding identity documents, our primary structural defense against large-scale money laundering is enforced transaction sizing. These limits apply to every swap across all supported asset pairs:
- Minimum per order: $100 USD equivalent in any asset.
- Maximum per order: $282,100 USD equivalent in any asset.
These limits are enforced by the swap engine and apply uniformly to every user. They prevent the platform from being used for industrial-scale layering while comfortably accommodating the needs of legitimate privacy-conscious traders seeking the best rates.
4. Pre-Trade Algorithmic Screening
"No AML holds" means we do not trap deposited funds pending document review. It does not mean we perform no checks at all. Our controls run before a swap order is accepted — not after your crypto has already arrived:
- Velocity monitoring: Our engine flags order patterns consistent with layering techniques — high-frequency, structured transactions across multiple pairs or amounts designed to obscure the origin of funds.
- Address screening: We maintain the capability to reject deposits from or to blockchain addresses identified as high-risk, including known ransomware wallets and sanctioned addresses, before the swap executes.
- Automatic refusal: Any transaction that triggers a severe risk threshold is automatically declined and refunded. No personal identity is requested or required for this process.
5. User Attestation
By initiating a swap on Stellar Swap, you confirm the following at the time of each transaction:
- The digital assets you are exchanging are legally owned and are not connected to criminal activity.
- You are not a sanctioned individual and are not acting on behalf of a sanctioned entity.
- Using a no-KYC cryptocurrency exchange does not violate the laws of your jurisdiction.
- You are transacting on your own behalf, not as an intermediary for undisclosed third parties.
6. Legal Cooperation
Stellar Swap will comply with legally binding orders from recognized jurisdictions. However, because our architecture is designed around zero data collection, what we can provide in response to any lawful request is strictly limited: order timestamps, blockchain addresses involved in specific transactions and session metadata. We cannot provide names, email addresses, IP address histories or user profiles because our system never collects them.
Users who suspect abuse of the platform by third parties are encouraged to report it to their local cybercrime authority.
7. Privacy Is Not a Legal Shield
Swapping crypto anonymously on Stellar Swap provides robust protection against corporate data harvesting and unnecessary surveillance. Using our platform does not provide immunity from prosecution under applicable law. Users who exploit our routing infrastructure to commit financial crimes remain fully liable under the laws of their jurisdiction.
8. Policy Updates
Our risk controls evolve as the threat landscape changes. We update our algorithmic defenses and this policy periodically. No mandatory KYC will ever be introduced as a result of these updates — our zero-collection architecture is a core platform commitment, not a feature subject to removal.
9. Contact
Questions about our risk controls or suspected abuse of the platform can be directed to support@changexlm.exchange.