Anti-Money Laundering Policy

Ninja Swap is committed to upholding the principles of financial integrity and combating financial crimes. However, we must be transparent about the technical limitations that affect our ability to enforce traditional AML measures:

• Privacy by Design: Our protocol is built with strong privacy-preserving technologies that limit our ability to monitor, track, or intervene in transactions.
• Minimal Data Collection: We intentionally do not collect or store personally identifiable information that would enable traditional KYC (Know Your Customer) verification.
• Decentralized Operation: Many aspects of the protocol operate in a decentralized manner on the Solana blockchain, outside of our direct control.

Due to these fundamental aspects of our service, traditional AML enforcement mechanisms cannot be implemented without compromising the core privacy features that define our platform.

Given our limited ability to enforce AML measures directly, users bear significant responsibility:

• Legal Compliance: Users are solely responsible for ensuring their use of Ninja Swap complies with all applicable laws and regulations in their jurisdiction.
• Prohibited Activities: Users are strictly prohibited from using Ninja Swap for:
  • Money laundering
  • Terrorist financing
  • Fraud or deception
  • Tax evasion
  • Transactions related to illegal goods or services
  • Any other activity that violates applicable law
• Assumption of Risk: Users acknowledge that by using a privacy-preserving protocol, they assume responsibility for their own compliance with financial regulations.

It is technically impossible for Ninja Swap to:

• Monitor individual transaction patterns for suspicious activity
• Implement transaction screening against sanctions lists
• Verify the source of funds for transactions
• Block specific transactions based on risk assessment
• Identify the ultimate beneficial owners behind wallet addresses
• Create detailed audit trails linking transactions to identities

These limitations are not oversights but intentional design choices to protect user privacy. They represent fundamental constraints on our ability to implement traditional AML controls.

Despite these limitations, we remain committed to financial integrity. Where technically possible without compromising our privacy guarantees, we will:

• Maintain clear policies prohibiting illegal use of our platform
• Cooperate with law enforcement within the constraints of our technical abilities
• Educate users about their compliance responsibilities
• Stay informed about regulatory developments in crypto privacy tools
• Be transparent about our technical limitations regarding AML enforcement

The privacy-preserving nature of our protocol creates significant challenges for traditional AML enforcement:

• Jurisdictional Complexity: Users may be subject to different AML regulations based on their location. We cannot reasonably determine which regulations apply to any given user.
• Limited Enforcement Mechanisms: We lack the technical ability to enforce geofencing or other restrictions based on jurisdiction.
• Regulatory Uncertainty: The regulation of privacy-preserving protocols is still evolving globally, creating ambiguity about compliance requirements.

Users must independently determine whether their use of Ninja Swap complies with their local regulations. Using this service may be incompatible with the regulatory requirements in certain jurisdictions.

In the event of lawful requests from government authorities:

• We will cooperate with legitimate law enforcement inquiries to the extent technically possible.
• However, due to our minimal data collection practices, we may be unable to provide meaningful information regarding specific users or transactions.
• We cannot access or decrypt private transaction data that is protected by the protocol's cryptographic mechanisms.
• Any assistance we can provide will be strictly limited to information that is actually in our possession and technically accessible.

Ninja Swap presents inherent AML/KYC compliance risks:

• Regulatory Risk: Users may face regulatory action if they use privacy tools in a manner prohibited by their local regulations.
• Compliance Risk: Financial institutions may have policies against interacting with privacy-preserving protocols.
• Record-Keeping Risk: Users subject to financial reporting requirements must maintain their own compliant records.

DISCLAIMER: Ninja Swap does not provide legal, tax, or compliance advice. Users should consult with qualified professionals regarding their specific circumstances and compliance obligations.

We acknowledge the evolving regulatory landscape around privacy-preserving technologies:

• We will monitor regulatory changes that may impact privacy tools in blockchain ecosystems.
• Where technically possible without compromising our core privacy guarantees, we will adapt our practices to align with emerging regulatory standards.
• We support efforts to develop privacy-preserving solutions that can achieve both strong user privacy and regulatory compliance.

However, users should understand that significant changes to our privacy model are unlikely, as they would fundamentally alter the nature and purpose of our service.

By using Ninja Swap, users explicitly acknowledge and agree that:

• They bear sole responsibility for ensuring their use of the platform complies with applicable laws and regulations
• They will not use Ninja Swap for any illegal purpose
• They understand the limitations of our ability to enforce AML measures
• They accept the compliance risks associated with using privacy-preserving technology
• They will consult with appropriate legal and compliance professionals regarding their use of the platform

Users who cannot or will not comply with these requirements should not use our service.

For questions about this AML Policy, please contact:

compliance@ninjaswap.io

Please note that while we welcome inquiries, our ability to address specific concerns about transactions or users may be limited by the privacy-preserving design of our protocol.