AML Policy

1. Our Position

Retro Swap is a privacy-first Monero exchange. We do not perform Know Your Customer (KYC) checks, and we do not conduct AML wallet screening of any kind. We do not use blockchain analytics services to score, flag, or reject transactions based on the origin of funds. This is a deliberate architectural decision made at the time the platform was designed, not an oversight or an omission.

We believe financial privacy is a fundamental human right. Monero exists to provide that privacy at the cryptographic protocol level, and Retro Swap exists to make Monero accessible to anyone who wants it — without requiring them to pass through surveillance infrastructure on the way to getting there.

2. What We Do Not Do

• We do not screen deposit addresses against blockchain risk databases or watchlists
• We do not process transactions through Chainalysis, Elliptic, TRM Labs, or any equivalent service
• We do not assign risk scores to wallets or individual transactions
• We do not freeze, delay, or reject swaps based on the perceived source of funds
• We do not collect identity information that could be used for AML reporting purposes

3. Prohibited Activities

Although we do not screen transactions, every user remains fully responsible for the legality of their own activity. Using Retro Swap for any of the following purposes is strictly prohibited and constitutes a violation of these terms:

• Converting criminally obtained funds or laundering proceeds of crime of any kind
• Financing terrorist organizations or violent extremist activities
• Circumventing international sanctions regimes
• Processing ransomware payments or proceeds from darknet market activity
• Fraud, theft, or handling of stolen or misappropriated cryptocurrency
• Human trafficking, organized crime, or other serious criminal enterprises

4. Transaction Limits

We apply transaction limits as a basic operational parameter for exchange liquidity management:

• Minimum transaction: Equivalent to $100 USD
• Maximum transaction: Equivalent to $282,100 USD

These limits are set for operational and liquidity reasons. They are not AML controls and should not be interpreted as such.

5. User Representations

By using Retro Swap, you represent and warrant that:

• The funds you are exchanging are legally obtained and are not the proceeds of any criminal activity.
• You are not currently subject to sanctions imposed by the United Nations, European Union, or other applicable international bodies.
• Your use of the Service does not violate any laws applicable to you in your jurisdiction.
• You will not use the Service to assist any third party in conducting illegal financial activity of any kind.

6. No Safe Harbor

Using a no-KYC, no-AML service does not shield anyone from criminal liability. Users who engage in illegal financial activity through any platform — including this one — remain fully liable under the laws of their jurisdiction. The absence of identity collection on our end does not mean the absence of legal accountability on yours.

7. Legal Cooperation

Retro Swap will cooperate with legitimate law enforcement requests where legally required to do so. Given our minimal data retention by design, the information we are able to provide in such circumstances is extremely limited. We retain no identity data, no persistent order history linked to individuals, and no wallet screening records.

8. Policy Updates

This policy may be updated periodically to reflect changes in how we operate. Any changes will be posted on this page with a revised date.

9. Contact

For questions about this policy, contact us at support@retroswap.exchange.