This Compliance Policy describes PriveFlow’s approach to anti-money laundering (AML), counter-terrorist financing (CTF), sanctions compliance, and financial crime prevention.
1. Our Model
PriveFlow does not:
- Hold, custody, or control user funds at any point
- Accept fiat currency
- Operate as a mixer or tumbler
- Pool, blend, or obscure funds from multiple users
PriveFlow does:
- Route transactions through established third-party exchange providers that perform their own compliance
- Rely on those providers’ AML/KYC/sanctions screening
- Refuse service to users in prohibited jurisdictions
- Cooperate with lawful requests from competent authorities
2. PriveFlow Is Not a Mixer
PriveFlow is a routing service, not a mixer or tumbler. Funds are never pooled across users. Each transaction is routed across independent exchange providers to convert between currencies. The side effect is severing the direct on-chain link between sender and receiver, achieved through legitimate exchange, not cryptographic mixing or aggregating of multiple users’ funds.
3. Exchange Partner Due Diligence
Before integrating a provider, we evaluate their compliance posture, AML/CTF policies, sanctions screening, and operational history. Active partners are reviewed periodically.
Current partners: ChangeNOW, ChangeHero.
4. Sanctions Compliance
We comply with OFAC, UN, EU, and UK HMT sanctions regimes. Destination addresses are screened by our exchange partners against sanctions lists. Addresses flagged as sanctioned may have their funds frozen or returned per partner policy.
5. AML/CTF Framework
Because PriveFlow is non-custodial, primary AML/CTF screening is performed by our exchange partners, who are responsible for their own regulatory compliance. PriveFlow retains transaction data for only 72 hours to minimize honeypot risk.
6. User Responsibilities
By using the Service, users represent they:
- Are not subject to sanctions
- Are not evading AML/KYC obligations
- Are not funding illegal activity
- Will comply with all applicable laws including tax laws
7. Law Enforcement Cooperation
We cooperate with valid, legally binding requests from competent authorities. Due to the 72-hour retention window, we may have no data to produce for older transactions.
Requests: [email protected]
8. Contact
Compliance matters: [email protected]
Law enforcement: [email protected]