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) a maximum size for swaps Cambio fulfils itself; (c) Cambio's own blocklist and watchlist of addresses; (d) ongoing monitoring for patterns indicative of layering or structuring.
2. Screening on Every Swap
Cambio checks the destination (payout) address of every swap, regardless of size, against the OFAC sanctions list and Cambio's own blocklist before a deposit address is issued. On orders Cambio fulfils itself, the sending address of the deposit is checked against the same lists when it arrives, and the destination address is checked again. On orders fulfilled by a liquidity provider, the deposit goes to that provider, which applies its own checks under its own terms. Customers must clear Cambio's applicable checks before the swap proceeds.
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 an address involved in the swap is on a watchlist Cambio maintains 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 checks the destination (payout) address of every swap, and the sending address of each deposit it receives on orders it fulfils itself, 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 Cambio refreshes at least daily. The check is an exact match on the address; Cambio does not trace transaction histories.
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: a swap paying to one is refused before a deposit address is issued. Funds Cambio receives from a sanctioned address are frozen pending instruction from the relevant regulatory authority; they are not returned to the sender absent such instruction.
4. Blocklist and Watchlist
In addition to the OFAC list, Cambio maintains its own blocklist of addresses it has identified as linked to fraud, theft, ransomware or other illicit activity: a swap paying to a blocklisted address is refused, and funds Cambio receives from one are frozen, exactly as for a sanctioned address. Cambio also maintains a watchlist: a deposit Cambio receives from a watchlisted address is paused for enhanced due diligence (Sections 2 and 5).
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, a deposit Cambio received will be returned to the sender wallet less network fees — except funds frozen under Section 3 or Section 4, which are not returned automatically.
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
Swaps Cambio fulfils itself are subject to a maximum size, applied as a risk-based control; swaps filled by a liquidity provider are subject to that provider's limits, shown on the quote.
10. Contact
For AML-related questions, contact [email protected]. For specific swap-related compliance questions, use [email protected] or open a ticket at /support and reference your order ID.