1. Framework
Cambio applies a risk-based AML framework consistent with the FATF Recommendations for virtual-asset service providers. Our framework is calibrated to the risk profile of a non-custodial software interface: no accounts, no stored balances, and no ongoing custody (funds are received only for the period required to complete an order), zero fiat exposure (we do not offer fiat on/off ramps), and a fixed catalogue of supported assets and networks.
The framework includes: (a) sanctions screening on every swap; (b) transaction-amount thresholds for enhanced due diligence; (c) risk-based review of the source (deposit) and destination (payout) addresses; (d) ongoing monitoring for patterns indicative of layering or structuring.
2. Screening on Every Swap
Cambio performs automated sanctions-list screening on the source (deposit) and destination (payout) wallet addresses of every swap, regardless of size. The vast majority of swaps clear this screening within seconds and proceed automatically.
Cambio does not impose a fixed USD or cryptocurrency threshold above which identity verification (KYC) is required. Identity verification is not a routine condition of using the Service.
Cambio may, at its sole discretion, request enhanced due diligence — including identity verification (performed through our regulated verification partner, Didit) or documentary evidence of the source of funds — for any swap, regardless of size, where the source or destination address triggers risk indicators or where Cambio has reasonable grounds to suspect that the funds are linked to criminal activity. Cambio applies enhanced due diligence narrowly to the specific swap in question.
3. Sanctions Screening
Wallet-address screening: Cambio screens the source (deposit) and destination (payout) wallet addresses of every swap against the U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List — the authoritative published source of sanctioned cryptocurrency wallet addresses — which is refreshed daily.
Name and entity screening: where a swap is escalated for enhanced due diligence, the individual is screened by name, through our verification partner Didit, against international watchlists — including the United Nations Security Council, European Union, and United Kingdom sanctions lists and politically-exposed-person (PEP) databases.
Wallet addresses that match a sanctioned entity are blocked from using the Service. Funds sent from a sanctioned address are frozen pending instruction from the relevant regulatory authority; they are not returned to the sender absent such instruction.
4. On-Chain Address Risk
In addition to sanctions-list screening, Cambio applies risk-based review to the source (deposit) and destination (payout) addresses of a swap. Addresses associated with darknet markets, ransomware, mixers, or other illicit activity may be blocked or subjected to enhanced review.
We do not block addresses solely based on association with privacy-preserving protocols (e.g., legitimate mixers, CoinJoin transactions) where no other risk indicators are present.
5. Source of Funds
For swaps requiring enhanced due diligence, Cambio may request documentary evidence of the source of the cryptocurrency being exchanged. Acceptable evidence includes (without limitation): transaction history from a previous regulated exchange, mining pool payout records, employer payment records denominated in cryptocurrency, or attestation of ownership over a long-held wallet.
Source-of-funds documentation is reviewed by Cambio compliance personnel and destroyed after the swap is cleared, except where retention is required by law.
6. Reporting Obligations
Cambio cooperates with valid information requests from regulatory authorities and law enforcement bodies in the Republic of Panama and in jurisdictions where we are legally obligated to respond. Where required by applicable law, Cambio files suspicious activity reports (SARs) with the relevant financial intelligence unit.
Cambio does not voluntarily disclose user data to third-party authorities absent a valid legal order or applicable legal obligation.
7. User Cooperation
If Cambio requests information from you as part of an AML review, your cooperation is required to complete the swap. If you decline to provide the requested information or the information you provide does not satisfy our compliance obligations, the deposit will be returned to the sender wallet less network fees.
You will not be penalized for declining a review request; the swap simply will not be completed.
8. Geographic Restrictions
The Service is not available to, and may not be used by, persons located or resident in: the United States and its territories, the United Kingdom and its Crown Dependencies, the European Union and EEA, China, Belarus, Turkey, Panama, Saint Vincent and the Grenadines, and any jurisdiction subject to comprehensive United Nations or OFAC sanctions (North Korea, Iran, Syria, Cuba) or the Russia-occupied regions of Ukraine. Compliance with this restriction is your responsibility. Cambio reserves the right to use various methods to prevent use of the Service from these jurisdictions, and you must comply even if those methods are ineffective or can be bypassed. Sanctioned jurisdictions remain subject to technical enforcement, and sanctions screening is applied to deposit and payout addresses on every swap.
You remain responsible for ensuring that your use of the Service is lawful in the jurisdiction in which you are located.
9. Transaction Limits
At launch, individual swaps are subject to a maximum size (approximately USD 1,000 equivalent per swap), applied as a risk-based AML control. Limits may be reviewed and adjusted over time.
10. Contact
For AML-related questions, contact legal@cambio.one. For specific swap-related compliance questions, use support@cambio.one or open a ticket at /support and reference your order ID.