AML Policy

Introduction

Throughout this Policy, all terms and conditions shall be construed and interpreted in conjunction with the definitions and provisions outlined in the Terms and Conditions.

Swapteria, operated by HRDT FINANCE LLC (“we”, “us”, or “our”), recognises the adverse effect of financial crime and is committed to conducting its activities with integrity, respecting its regulatory, ethical and social responsibilities.

We are committed to:

• protecting users, staff, contractors, partners and others with whom we do business;
• supporting governments, regulators and law enforcement in wider economic crime prevention;
• preventing misuse of our platform for money laundering, terrorist financing, fraud, sanctions evasion or other unlawful activity.

HRDT FINANCE LLC will not tolerate any deliberate breach of financial crime laws and regulations applicable to its business activities.

Money Laundering and Terrorist Financing

Money laundering means any act or attempt to conceal, disguise, convert, transfer, or use funds or assets derived from illegal activities in order to make them appear legitimate.

Terrorist financing means the provision, collection or use of funds, directly or indirectly, with the intention or knowledge that such funds may be used to support terrorist activity or organisations.

Terrorist financing may involve both illicit and legitimately obtained funds. Small amounts may be sufficient to support terrorist activity, making detection and monitoring particularly important.

Scope of the AML/CFT Policy

This AML/CFT Policy covers the following matters:

• internal controls;
• governance;
• customer due diligence;
• transaction monitoring and risk assessment;
• risk-based approach;
• staff training;
• record keeping;
• policy updates.

Internal Controls

HRDT FINANCE LLC maintains internal controls designed to comply with applicable AML/CFT laws, regulations and internal risk management standards.

These controls include, but are not limited to:

• establishing and verifying user identity;
• screening users against sanctions, watchlists and politically exposed persons lists;
• identifying unusual or suspicious activity;
• facilitating the reporting of suspicious activity where required;
• retaining user documentation and transaction history;
• applying enhanced due diligence where appropriate.

Internal controls are reviewed periodically to ensure their effectiveness and alignment with the company’s risk profile and applicable legal requirements.

Governance

The AML Compliance Officer is responsible for establishing, maintaining and overseeing the AML/CFT compliance framework of HRDT FINANCE LLC.

The responsibilities of the AML Compliance Officer include, but are not limited to:

• developing and updating AML/CFT policies and procedures;
• overseeing customer identification and verification processes;
• implementing and maintaining record keeping procedures;
• reviewing unusual or suspicious transactions;
• submitting reports to appropriate authorities where required;
• responding to lawful requests from regulators and law enforcement;
• organising AML/CFT training for relevant staff;
• updating the company’s risk assessment on a regular basis.

Customer Due Diligence

HRDT FINANCE LLC applies a risk-based customer due diligence framework, including customer identification, verification and Know Your Customer procedures.

Before establishing a business relationship or allowing access to services, users may be required to provide identification information and supporting documents.

Customer due diligence may include verification of identity, screening against sanctions and watchlists, politically exposed person checks, and assessment of the user’s risk profile.

Where applicable, enhanced due diligence may be applied to higher-risk users, transactions or jurisdictions.

HRDT FINANCE LLC may use third-party service providers to support customer due diligence, identity verification, sanctions screening, monitoring and compliance checks.

Transaction Monitoring and Risk Assessment

HRDT FINANCE LLC applies transaction monitoring and risk assessment measures to detect unusual, suspicious or potentially unlawful activity.

In relation to AML/CFT risk, HRDT FINANCE LLC may:

• monitor user transactions on an ongoing basis;
• request additional information or documents to confirm Source of Funds or Source of Wealth;
• suspend, delay or decline transactions where suspicious activity is identified;
• restrict, suspend or terminate user accounts where there is reasonable suspicion of unlawful activity;
• report suspicious activity to competent authorities where required by law.

Transactions may be considered suspicious where they are inconsistent with a user’s known profile, expected behaviour, usual activity or available information.

User risk profiles may be assessed as low, medium or high and may be reviewed periodically or upon trigger events.

Training

Relevant staff receive AML/CFT training appropriate to their roles and responsibilities.

Training is designed to ensure that staff understand applicable AML/CFT obligations, internal procedures, suspicious activity indicators and reporting requirements.

Training may be conducted periodically and updated where required due to changes in law, regulation, business activity or internal procedures.

Record Keeping

Record keeping is an essential component of the AML/CFT compliance program and supports financial crime prevention, investigation and regulatory compliance.

HRDT FINANCE LLC may retain records including, but not limited to:

• customer identification and verification information;
• customer due diligence records;
• transaction records;
• risk assessments;
• internal reviews and investigations;
• suspicious activity reports where applicable;
• staff training records.

Policy Changes

We reserve the right to modify, amend or update this Policy at any time to reflect changes in our business practices, legal requirements, regulatory expectations or internal procedures.

Any changes to this Policy will become effective upon publication on our website or through other appropriate communication channels.

By continuing to use our services after any changes become effective, you acknowledge and agree to the updated Policy. If you do not agree with the revised Policy, you should discontinue use of our services.

Contact

If you have any questions regarding this AML Policy, please contact us at [email protected].