Smart Tech Support Limited (hereinafter referred to as the “Company”), a company incorporated under the laws of Samoa with registration number 94021 and registered address at Intershore Suite, Le Sanalele Complex, PO Box 608, Apia, Samoa, strictly adheres to international standards for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT), including the recommendations of the Financial Action Task Force (FATF).

This AML/KYC Policy (hereinafter referred to as the “Policy”) establishes mandatory procedures for identification, monitoring, and reporting.

1. Scope of Application

This Policy applies to all Users of the Allswaps NFT Platform without exception. The Company conducts risk-based checks at all stages of interaction with Users in accordance with the principle of proportionality of risk.

You are not permitted to use the Platform if you are located in, incorporated in, a resident of, or otherwise subject to the laws of the following jurisdictions: Afghanistan, American Samoa, the United States Virgin Islands, Guam, Iran, Yemen, Canada, the Kingdom of the Netherlands, Cuba, Libya, Pakistan, the State of Palestine, Puerto Rico, Somalia, North Korea, the Northern Mariana Islands, the United States, Syria, the Russian Federation, the Republic of Belarus, the Republic of Sudan, Transnistria, Abkhazia, South Ossetia, the Turkish Republic of Northern Cyprus, Western Sahara, the Federal Republic of Ambazonia, Kosovo, Crimea and the temporarily occupied territories of Ukraine, any member state of the European Union (EU) or the European Economic Area (EEA), as well as any other jurisdictions subject to sanctions imposed by the United Nations Security Council.

2. Identification Approach

The Company follows a principle of minimal identification by default. Standard access to the Platform is provided through the connection of a cryptocurrency wallet without the mandatory submission of identity documents.

2.1. Basic Identification (Tier 1)

Basic identification is performed automatically upon wallet connection and includes:

analysis of the wallet address using blockchain analytics tools.
review of the transaction history for potential links to suspicious addresses.
screening against applicable sanctions lists (including OFAC SDN, EU, and UN sanctions lists).

2.2. Enhanced Identification (Tier 2)

Enhanced identification is performed when completing verification tasks and may include:

validation of the e-mail address (confirmation via e-mail).
verification of the Telegram account (via bot).
verification of the X/Twitter account.
checks for disposable or spam accounts.

2.3. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) may be applied in cases of increased risk, including but not limited to:

abnormal activity (such as multiple mints or atypical usage patterns).
connections between the wallet and mixers, darknet markets, or sanctioned addresses.
requests from regulators or law enforcement authorities.
suspicion of a Sybil attack or the use of multiple accounts.

In the case of EDD, the Company may request the User to provide: an identity document (passport or national ID), proof of residential address, and an explanation of the source of funds.

Verification may be conducted through a trusted third-party provider (such as SumSub or a similar service). Refusal to undergo EDD may result in suspension or termination of access to the Platform.

3. Automated AML Screening

The Company uses automated tools for the following purposes:

real-time transaction monitoring to detect suspicious patterns;
assigning a risk score to each wallet.
daily screening of the user database against updated sanctions lists (including OFAC SDN, EU, UN, and national sanctions lists).
detection of transactions associated with mixers, darknet markets, or scam-related projects.
in the event that suspicious activity is detected, a transaction may be automatically rejected or blocked pending additional review.

4. Suspicious Activity Reporting

In accordance with applicable law, the Company undertakes to:

submit Suspicious Activity Reports (SAR/STR) to competent authorities when required.
maintain the confidentiality of the filing of such reports (tipping-off is strictly prohibited).
retain records of all transactions and compliance checks for at least five (5) years, with the possibility of audit.
cooperate with law enforcement authorities where lawful grounds exist.

5. Compliance Officer

The designated Compliance Officer is responsible for the implementation of this Policy, monitoring its compliance, providing staff training, and liaising with regulatory authorities. Contact details of the Compliance Officer may be provided upon a justified request.

6. Staff Training

All Company personnel who have access to User data or are involved in compliance processes undergo mandatory annual training on AML/KYC matters, including the identification of suspicious transactions, reporting procedures, and current regulatory requirements.

7. User Obligations

The User agrees to:

provide accurate and truthful information.
promptly notify the Company of any suspicious activity related to their account.
cooperate with the Company during compliance checks and investigations.
refrain from using the Platform for money laundering, terrorist financing, or any other unlawful activities.
refrain from using funds originating from illegal sources.

8. Sanctions for Violations

In the event of a violation of this Policy, the Company reserves the right to:

immediately suspend or terminate the User’s access to the Platform.
revoke all NFTs, Energy, and rewards associated with the User.
report the violation to competent law enforcement authorities.
take any other actions permitted under applicable law.

9. Internal Audit

The Company conducts regular internal audits of its AML/KYC procedures (at least on a quarterly basis), with the involvement of external consultants where necessary. The results of such audits are used to improve and enhance compliance procedures.

10. Contact Information

For inquiries related to AML/KYC: support@allswaps.com

Smart Tech Support Limited
Intershore Suite, Le Sanalele Complex
PO Box 608
Apia, Samoa