XExchange AML Policy
Effective date: September 23, 2026
XExchange uses a risk-based approach to transaction review. The standard exchange flow does not require a persistent trading account, but that does not mean every transaction is automatically exempt from AML, sanctions, fraud or security controls.
This policy explains the circumstances in which a transaction can be reviewed and what may happen when additional checks are required.
No Account Registration and AML Review Are Different
Account registration describes whether a user must create and maintain a conventional profile before starting an exchange.
AML review describes the risk controls applied to a particular transaction.
XExchange can therefore operate a standard no-account flow while still reviewing an order when risk indicators require additional attention.
The service does not make a universal no-KYC guarantee.
Risk-Based Transaction Screening
XExchange may apply automated or manual risk checks to transaction information associated with an order.
The purpose can include identifying indicators connected with:
- sanctions exposure;
- stolen or compromised funds;
- fraud or scams;
- ransomware or other illicit activity;
- unusual or inconsistent transaction patterns;
- attempts to abuse the exchange service;
- security concerns or technical anomalies;
- other high-risk blockchain activity relevant to the transaction.
The exact screening methods and internal thresholds are not published because doing so could weaken the controls.
When Additional Review May Be Required
A transaction can require additional review when the information available to XExchange indicates elevated risk or when the order cannot safely continue under the standard automated flow.
Examples can include:
- a source transaction associated with material risk indicators;
- sanctions-related concerns;
- transaction details that conflict with the order;
- suspected fraud, theft or unauthorized use;
- attempts to bypass service restrictions;
- a request from a relevant service provider involved in the transaction flow;
- other circumstances requiring manual compliance or security review.
These examples do not mean that every transaction in one category will receive the same outcome.
Additional Information or KYC
If a transaction requires further review, XExchange may request information reasonably necessary to assess that specific case.
Depending on the circumstances, this can include:
- confirmation of transaction ownership or control;
- explanation of the transaction purpose;
- information about the source or destination of funds;
- supporting transaction records;
- identity or other KYC information when required for the review.
XExchange should not request more information than is necessary for the specific review.
A wallet seed phrase or private key is never an appropriate AML or KYC document.
Prohibited Activity
XExchange must not be used to facilitate activity that the service determines it cannot process under its risk controls.
This can include transactions connected with:
- sanctioned persons or entities;
- stolen assets;
- fraud, scams or unauthorized account access;
- ransomware;
- money laundering or terrorist financing;
- deliberate abuse of the exchange infrastructure;
- attempts to conceal activity in order to bypass applicable service controls.
This policy does not attempt to provide an exhaustive list of every illegal or high-risk activity.
Sanctions and High-Risk Transactions
A transaction associated with sanctions or other material high-risk indicators can be delayed, reviewed, declined or otherwise restricted according to the circumstances of the order.
XExchange does not publish a list of guaranteed outcomes because blockchain transactions can differ materially in source, destination, route and recoverability.
Possible Order Outcomes
When a transaction enters review, possible outcomes can include:
- the order continuing after review;
- a request for additional information;
- temporary hold while the transaction is assessed;
- the exchange being declined;
- a return or refund when technically possible and appropriate;
- another outcome required by the specific transaction circumstances.
A refund cannot be guaranteed in every case. Network conditions, transaction state and destination infrastructure can affect what is technically possible.
Transaction Information Used for Review
Risk review can use information already associated with the order, such as:
- wallet addresses;
- transaction hashes;
- selected assets and networks;
- amounts;
- order timestamps and status;
- blockchain-risk indicators;
- support or compliance communication.
Handling of this information is also subject to the XExchange Privacy Policy.
Privacy and AML Boundaries
Privacy-focused service design does not mean compliance controls are disabled.
XExchange separates three concepts:
- no persistent account registration in the standard flow;
- blockchain privacy, which depends on the assets and networks involved;
- transaction-specific AML or security review when required.
This distinction keeps commercial privacy claims consistent with the actual transaction-review model.
Contact the Compliance Team
AML and transaction-review questions can be sent to [email protected].
For an order-specific question, include the XExchange order ID and relevant blockchain transaction hash.
Do not send a seed phrase, private key, wallet password or one-time authentication code.
General order support is available at [email protected].
Related Policies
FAQ
Does XExchange require KYC for every transaction?
No universal statement applies to every order. The standard flow is no-account, while additional information or KYC may be requested when a transaction requires further review.
Why can an order be reviewed?
A review can be triggered by risk, sanctions, fraud, security or transaction-consistency concerns associated with the specific order.
What information can XExchange request?
The service may request information reasonably necessary for the review, which can include transaction context, source/destination information, supporting records or identity information when required.
Can an order be declined?
Yes. A transaction can be declined when XExchange determines that it cannot continue under the applicable risk or security controls.
Will funds always be refunded if an exchange is declined?
A refund cannot be guaranteed in every case. The possible outcome depends on the transaction state, network, technical recoverability and review circumstances.
Does privacy-focused mean AML checks are disabled?
No. Privacy-focused exchange design and transaction-specific compliance review are separate concepts.
How do I contact compliance?
Email [email protected] with the order ID and transaction hash when the question relates to a specific exchange.