AML Policy

Every incoming transaction is screened for AML and sanctions exposure before it is credited; screening cannot be disabled on any account or configuration. Two screening levels are available. Basic is included in the service rate; the specific checks it performs are not published. Extended additionally routes every transaction through independent blockchain-analytics providers for deeper verification. The screening level can be set for an organization, a project, or an individual payment; the most specific setting applies. Regardless of level, exposure to sanctioned jurisdictions is blocked in the processing pipeline, transaction patterns are monitored continuously, and funds that fail screening are never credited as a spendable balance.

Screening runs on every incoming transaction — a Payment or a Static Wallet deposit — before it is credited to a balance. It cannot be turned off for any account, project, or payment; there is no configuration that skips it. Screening happens while the transaction is still pending, in parallel with confirmation tracking, so it is never a separate step added after the fact.

Exposure to sanctioned jurisdictions is blocked automatically in the processing pipeline, not left to manual review after the fact. A transaction linked to a sanctioned jurisdiction or a sanctioned party is stopped before it reaches a spendable balance, regardless of the screening level configured on the account.

Beyond the check performed on each transaction, Suward monitors transaction patterns continuously. Activity that looks structured, unusually repetitive, or inconsistent with the merchant's stated business can trigger a hold even after an individual transaction has passed its initial check.

A transaction held for review moves to complianceHold and is not credited while the review runs. If the review clears it, the transaction proceeds normally; if it doesn't, it ends as complianceRejected and nothing is credited — on a Static Wallet deposit that had briefly shown as credited, the credit is reversed. Suward does not publish the internal criteria that trigger a hold; doing so would let bad actors route around the check.

You may not use Suward for activity that is illegal in your jurisdiction or ours, including money laundering, terrorist financing, sanctions evasion, fraud, or financing of any prohibited activity. You are responsible for the legality of the products and services your business sells; Suward screens the payment, not your business model.

There is no onboarding review before your first payment — screening runs on every transaction from the first one instead. That does not reduce what is expected of you: you are responsible for the accuracy of the business information in your account, for using Suward only for lawful activity consistent with what your account represents, and for not structuring payments to stay under a threshold or otherwise route around screening. Suward may request additional information about your business or about a specific transaction at any time, and may suspend an account while it reviews a request.

For a vendor review or a due-diligence questionnaire, contact payments@suward.com and reference this Policy directly. Program specifics beyond what is published here are provided on request, not published generally.

Screening records and the transaction data behind them are retained for as long as applicable financial-compliance law requires, regardless of whether the account is later closed. [TO CONFIRM: the specific retention period in years — not specified in current source material]

Suward cooperates with law enforcement and regulators investigating money laundering, sanctions evasion, or fraud, including responding to lawful requests for account and transaction records. [TO CONFIRM: which regulator(s) or jurisdiction's authorities Suward is directly accountable to — not stated anywhere in current site content]

We may update this Policy; material changes are announced on this page and, for account holders, through the dashboard or by email.