Financial crime and sanctions

Why SwapEazi, which moves no money, runs no customer due diligence programme, and what it still does to keep its service from being misused.

1. Why SwapEazi has no customer due diligence programme

SwapEazi measures what cross-border payments cost. It does not accept, hold, move, exchange or pay out money for anyone, and it does not arrange or execute payments. Every payment a customer makes goes through their own bank or payment provider, which carries out its own customer due diligence, sanctions screening and reporting.

Because it carries on none of the businesses listed in Schedule 1 to the Financial Intelligence Centre Act 38 of 2001, SwapEazi is not an accountable institution. It therefore does not verify customers' identities, monitor transactions or file reports as an accountable institution does, and it does not collect identity documents.

SwapEazi built a payment service before September 2026, with an anti-money laundering programme to match. That service is closed and its endpoints answer every request with an error. Records from it are handled as our Privacy Policy describes.

2. What we still do

• We do not knowingly provide the service to anyone subject to sanctions imposed by the United Nations Security Council or listed under South African law, or to anyone acting for them.
• Our Terms prohibit using SwapEazi for anything unlawful, including planning, concealing or disguising the proceeds of crime or the financing of terrorism. We suspend access where we have grounds to believe it is being used that way.
• Where the law requires it, we report a suspicious matter to the Financial Intelligence Centre or cooperate with a lawful request from a competent authority, even though we are not an accountable institution.
• We ask for payment economics, not personal information, and keep audit files only as long as our Privacy Policy states, so we hold as little as possible that could be misused.

3. What SwapEazi's figures are, for a compliance reviewer

A SwapEazi assessment or audit measures the cost of a payment against an independent market reference and shows which providers serve a route. It does not assess whether a payment, payer or beneficiary is lawful, and must not be relied on as sanctions screening, customer due diligence or a compliance approval. Those remain the responsibility of the paying business and its bank or provider.

Signed records produced by SwapEazi can be kept with a payment file as evidence of what a payment was expected to cost and what it cost. Anyone can verify their signature without an account.

4. Contact

Questions from a bank's, provider's or auditor's compliance team go to hello@swapeazi.io. We answer them in writing.

Contact

Questions or requests under this policy: hello@swapeazi.io