AML & Acceptable Use Policy
Last updated: 2026-06-19
Why this policy exists: protection against money laundering and legal requirements.
1. Purpose
Compliance with anti-money-laundering (AML) and counter-terrorist-financing (CFT) laws. We follow the AML/CFT obligations applicable in our jurisdiction of establishment.
2. Scope
This policy applies to Suward, to merchants who use Suward to accept payments, and to the beneficiaries who receive them. It governs how we detect and prevent money laundering, terrorist financing, and sanctioned activity across the service.
3. Customer Due Diligence
Onboarding does not require upfront business-verification paperwork. We collect what is needed for AML/CFT compliance. Where legally required, Suward reserves the right to conduct risk-based checks on any account.
4. Prohibited Activities / Acceptable Use
Money laundering, sanctioned transactions, illegal goods or services, fraud, darknet, weapons, and similar. This is the Acceptable Use referenced from Terms of Service §5.
5. Sanctions Screening
We screen against sanctions lists and refuse service from sanctioned jurisdictions.
6. Transaction Monitoring
Detecting suspicious activity; the right to delay or freeze a withdrawal on suspicion (see Terms of Service §8).
7. Suspicious Activity Reporting
We report suspicious activity to the competent authority in our jurisdiction of establishment.
8. Record Keeping
We retain transaction records and any compliance data we collect for the periods required by applicable law (see Privacy Policy §8, retention).
9. Consequences of Violations
Suspension or closure of the account, withholding of funds, and notifying the authorities.
10. Cooperation with Authorities
Where legally compelled, Suward cooperates with competent authorities and responds to lawful requests relating to accounts and transactions on the service.
11. Changes
We may update this policy as the law or the service changes. Material changes are reflected here with a revised "last updated" date; continued use of the service after a change constitutes acceptance.
12. Compliance Contact
Reach us at hello@suward.com with any compliance questions about this policy.