▪️Compliance

Compliance is a foundational element of Houdini Swap's operation. We integrate regulatory, legal, and data privacy compliance into every layer of our product technology stack, showcasing our commitment to innovative yet responsible Web3 solutions. We adhere to, and operate under the policies and procedures detailed in the Houdini Swap Compliance Policy.

---

Legal and Regulatory Adherence

Our platform is strictly intended for lawful use, aligning with all necessary legal requirements. We ensure that our operational procedures are not only innovative but also rigorously adhere to leading industry standards, reflecting our dedication to operating within the legal framework.

---

Selective Exchange Partnerships

Partner exchanges are chosen through a meticulous curation process, focusing on non-custodial entities that maintain industry-compliant processes. Key features include:

• Real-Time AML Screening: Each transaction undergoes comprehensive, risk-based anti-money laundering (AML) screening in real-time.

• Ongoing Compliance Vetting: We routinely assess our exchange partners to ensure continuous compliance with required AML policies and procedures.

Houdini Swap is committed to upholding high compliance standards, ensuring every aspect of our service meets legal and regulatory requirements, and maintaining trust and reliability in our transactional services.

---

AML / ATF Compliance

Houdini Swap rigorously adheres to Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) standards through robust collaboration with exchange partners, ensuring compliance with regulatory requirements.

• Record Maintenance: Exchange partners maintain separate transaction records, with Exchange 1 documenting sender details and Exchange 2 handling receiver information. This separation prevents any single exchange from accessing complete transaction data.

• Operational Standards: Our partners are responsible for AML/ATF liabilities, following industry-standard procedures including real-time risk scanning and blocking transactions from sanctioned entities as per the U.S. Office of Foreign Assets Control (OFAC).

---

Houdini Swap Compliance Activity

Our compliance role has a focus on:

• Geo and TOR Blocking: We implement geo-blocking for OFAC-sanctioned countries and restrict access via TOR networks.

• System Efficacy Assessment: Our team periodically reviews aggregated sender wallet data, which we store for 72 hours, to evaluate the effectiveness of our partners’ AML/ATF systems and determine if enhancements are needed.