KYC and AML Policies

Last updated: December 11, 2021.

KYC Policy

  1. Preamble

1.1 We ensure that we comply with know-your-customer (KYC) and anti-money-laundering (AML) laws and regulations, and will not knowingly violate know-your-customers and anti-money-laundering policies. To the extent of our reasonable control, we will adopt necessary measures and technology to provide you with services that are safe and secure, to protect you against the loss caused by money laundering to the greatest extent possible.

1.2 Our know-your-customer and anti-money-laundering policies are a comprehensive system of international policies, including the know-your-customer and anti-money-laundering policies of the jurisdictions to which you are subject. Our robust compliance framework ensures that we meet regulatory requirements and regulatory standards on both the local and global levels, and ensure the operational sustainability of our Website.

  1. Content of Our Know-Your-Customer Policy

2.1 We promulgate and update know-your-customers policy to meet the standards set by relevant laws and regulations;

2.2 We promulgate and update some of the guidelines and rules in connection with the operation of this Website, and our staff will provide you whole-process service by the guidelines and rules;

2.3 We design and complete the procedures for internal monitoring and transaction control, such as rigorous identity authentication procedures, and form a professional team responsible for anti-money laundering;

2.4 We adopt a risk-prevention-based approach to carry out due diligence and continuous supervision in connection with customers;

2.5 Review and regularly inspect existing transactions;

2.6 To report suspicious transactions to the competent authorities;

2.7 Proof documents of identity documents, address certificates, and transaction records will be maintained for at least six (6) years; if they are submitted to the regulatory authorities, let it be understood that a separate notice will not be provided to you;

2.8 Credit cards are prohibited throughout the transaction;

2.9. If you are from any of the high-risk and non-cooperative jurisdictions listed on the website of Financial Action Task Force (FATF) of the United States, you will not be allowed to register as a member of this Website or use any service offered by this Website;

2.10 Regularly participate in the training organized by the relevant authorities and provide regular training to the staff.

  1. Identity Information and the Verification and Confirmation Thereof

3.1 Identity Information

3.1.1 By the laws and regulations of relevant jurisdictions and in light of the nature of entities concerned, the content of your information as is collected by us may vary, and in principle, we will collect the following information of yours if you register as an individual: 

Basic personal information: your name, address (and permanent address, if the two are different), date of birth and nationality, and other information available. Identity authentication shall be based on documents issued by the official or other similar authorities, such as passports, identity cards, or other identity documents as are required and issued by relevant jurisdictions. The address you provide will be validated in an appropriate manner, such as checking the fare ticket of the means of transportation you use, your interest rate bills, or voter registration.

Valid photo: before you register, you must provide a photograph showing you holding your identity document in front of your chest;

Contact information: telephone/mobile phone number and valid email address.

We may request you to provide further information under circumstances to meet our KYC and AML obligations under relevant laws and regulations.

3.1.2 If you are a company or any other type of legal entity, we will collect the following information of yours to determine the final beneficiary of your account or your trust account.

Your corporation enrollment and registration certificates of the company; a copy of the articles of association and memorandum of the company; the detailed certification materials of the ownership structure and ownership description of the company, and the decision of the board of directors on designating the authorized agent of the company responsible for the opening and execution of the account of the company with the website; the identity documents of the directors, major shareholders of the company as well as the authorized signatory for the company’s account with the website, as are required to be provided by relevant rules; the company’s main business address, and the company’s mailing address if it is different from the main business address of the company. If the local address of the company is different from its main business address, the company shall be deemed to be a high-risk customer, and consequently, the company will be required to provide additional documentation.

Other certification documents, documents issued by competent authorities, and other documents we may deem necessary in light of the laws and regulations of relevant jurisdictions and light of the specific nature of your entity.

We may request you to provide further information under circumstances to meet our KYC and AML obligations under relevant laws and regulations.

3.1.3 We only accept English version of your identity information; if your identity information is not in this language, you shall have your identity information translated into English and duly notarized.

3.2 Confirmation and Verification

3.2.1 You are required to provide both the front and back sides of your identity documents.

3.2.2 You are required to provide us with a photograph showing you holding your identity documents in front of your chest.

3.2.3 Copies of certification documents shall be checked against the originals thereof. Nonetheless, if a trusted and suitable certifier person can prove that such copies are accurate and comprehensive duplicates of the originals thereof, such copies shall be deemed as acceptable. Such certifiers include ambassadors, members of the judiciary, magistrates, etc.

3.2.4 The identification of the ultimate beneficiary and controller of the account shall be based on the determination of which individuals ultimately own or control the direct customer and/or to determining that the ongoing transaction is performed by another person. If you are a business enterprise, the identity of major shareholders thereof (for example, those holding 10 % or more of the voting equity in such business enterprise) shall be verified. Generally, a shareholder holding 25 % of the shares of the company will be deemed as involving an average level of risk, and the identity of the shareholder shall be verified; a shareholder holding 10 % or more of the voting rights or shares is deemed to be involving a high level of risk, and the identity of the shareholder shall be verified.

  1. Transaction Supervision

4.1 We constantly set and adjust daily trading and cash withdrawal limits based on security requirement and the actual state of transactions;

4.2 If the transaction occurs frequently in an account registered by you or is beyond reasonable circumstances, our professional team will assess and determine whether such a transaction is suspicious;

4.3 If we identify a specific transaction as suspicious based on our assessment, we may adopt such restrictive measures as suspending the transaction or denying the transaction, and if it is possible, we may even reverse the transaction as soon as possible, and report to the competent authorities, without, however, notifying you;

4.4 We reserve the right to reject registration applications by applicants that do not comply with the international standards against money laundering or who may be regarded as political and public figures; we reserve the right to suspend or terminate a transaction identified as suspicious based on our assessment, which, however, does not breach any of our obligations and duties to you.

AML Policy


Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firms’ knowledge or suspicion.

In response to the scale and effect of money laundering, the European Union has passed Directives designed to combat money laundering and terrorism. These Directives, together with regulations, rules and industry guidance, form the cornerstone of our AML/CTF obligations and outline the offenses and penalties for failing to comply.

Venice Swap senior management have implemented systems and procedures that meet the standards set forth by the European Union in order to prevent money laundering and not be used by criminals to launder proceeds of crime.


Venice Swap AML Policy is designed to prevent money laundering by meeting the European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

  • Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
  • Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
  • Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • Maintaining appropriate records for the minimum prescribed periods;
  • Providing training for and raising awareness among all relevant employees.


Venice Swap is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Venice Swap will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.