KYC, AML & Risk Policy
GhostSwap is designed to be KYC-free by default. This page gives a high-level overview of how we keep the vast majority of swaps verification-free while still complying with applicable anti-money-laundering (“AML”) and sanctions requirements for clearly high-risk cases.
Core Principles
GhostSwap is a privacy-first, non-custodial crypto swap service. Our goal is to let users exchange digital assets without opening an account and without routine identity checks, while still respecting the laws that apply to us and our partners.
To achieve this, we follow these principles:
1. KYC-Free for the Vast Majority of Swaps
In practice, well over 99.5% of all swaps on GhostSwap are completed without any identity verification. For normal, low-risk usage we do not ask for passports, selfies, proof-of-address, or similar data.
2. Targeted Checks Only
We do not run blanket KYC on all users. In a very small minority of clearly high-risk situations, our risk controls may require additional review, temporary holds, or limited verification in order to comply with AML and sanctions requirements.
3. Non-Custodial by Design
GhostSwap does not operate like a traditional custodial exchange. We do not hold user balances. Funds move from the sender’s wallet through the swap route to the destination wallet, with no long-term storage on our side.
4. Minimal Data, Short Retention
We collect and store only the data that is necessary to operate the service, manage risk, and comply with applicable law. Where verification is required, related data is retained only for as long as legally or operationally necessary, then securely deleted or anonymised.
Important: This policy describes how GhostSwap approaches KYC, AML and risk controls. It does not guarantee that any specific transaction will be accepted or completed. We may decline or cancel transactions at our discretion where we reasonably believe doing so is necessary to comply with law or manage risk.
How Our Risk Assessment Works
Digital assets can be abused for fraud, sanctions evasion and other illicit activity. To limit this risk, GhostSwap uses automated and manual controls to review certain transactions. These controls are designed to be proportionate and targeted, not to turn the platform into a fully KYC-based exchange.
Signals We May Consider
Without disclosing sensitive internal rules, our systems may consider factors such as:
- Known sanctions or watchlist exposure of addresses
- Association with publicly flagged stolen or hacked funds
- Patterns strongly associated with fraud or abuse
- Unusual transaction size, routing or behaviour
Possible Outcomes
When a swap triggers risk alerts, one of the following may occur:
- Swap proceeds normally after automated checks
- Swap is temporarily placed on hold for review
- Swap is declined and funds are refunded (where possible)
- Limited verification is requested before we proceed or refund
We do not publish detailed risk rules. Doing so would make it easier for bad actors to evade controls. However, we commit to using our risk systems in a fair, proportionate way that keeps GhostSwap usable for legitimate privacy-seeking users.
When We May Ask for Verification
In the overwhelming majority of cases, GhostSwap will not ask you for identity documents. However, if a transaction appears to carry unusually high risk, our team or our regulated partners may need more information in order to proceed or to issue a refund.
Types of Information We May Request
Depending on the situation and applicable law, this may include:
- Basic identity details (e.g. name, country of residence)
- Government-issued ID document
- Selfie or liveness check to match the document
- In some cases, information about the source of funds
Who Processes Verification
In some cases, verification may be processed directly by GhostSwap. In others, it may be carried out by a specialised third-party provider acting on our behalf. In both cases, data is handled in line with our Privacy Policy and applicable data protection laws.
Refusing verification: If you decline to provide requested information, we may not be able to proceed with the swap and may be unable to return funds in certain high-risk cases where doing so would breach sanctions or AML rules.
Declines, Refunds & Stuck Orders
While most swaps complete in minutes, a small number may be delayed, cancelled or refunded because of risk concerns, technical issues, or user error (for example, sending an unsupported asset).
Declined Transactions
We may decline a transaction if we reasonably believe that processing it would violate applicable law, sanctions, or our internal risk policies. Where possible and lawful, we will attempt to refund the original asset back to the address that sent it, minus any network fees or irrecoverable costs.
Refunds & Processing Time
Refund timing depends on blockchain congestion, liquidity, and the nature of the issue. In straightforward cases, refunds are usually processed as soon as practical. In higher-risk cases or where verification is required, refunds may take longer while checks are completed.
If you believe your swap is stuck, please use the transaction status tools available on GhostSwap and contact support with your order ID and transaction hash. Providing complete information helps us resolve your case faster.
Data Handling & Retention
GhostSwap follows a data minimisation model. We collect and retain only the information strictly required to operate the service, troubleshoot issues, and meet our legal obligations.
Standard Swaps (KYC-Free)
For ordinary swaps that do not trigger high-risk flags, we generally only process technical data such as wallet addresses, transaction hashes, routing details and basic device/usage logs. These are kept for limited periods to help with support, fraud detection and service analytics.
High-Risk & Verified Swaps
Where verification is required, we may temporarily store the documents and data you provide, together with associated transaction information. This data is restricted to authorised personnel and/or regulated verification providers and is retained only as long as required by law or our legitimate compliance needs.
For more detail on what we collect, how we use it, and your rights, please see our Privacy Policy.
User Responsibilities & Important Notices
GhostSwap is intended for lawful use only. By initiating a swap, you confirm that:
- You are not using GhostSwap in violation of any applicable law or sanctions.
- You are not using GhostSwap for fraud, money laundering, terrorism financing or other criminal activity.
- You understand that blockchain transactions are irreversible and that errors in the address, network, or asset you provide may result in permanent loss of funds.