CryptoRoute

AML Policy

Last updated: 2 July 2026

This Anti-Money Laundering Policy ("Policy") describes the measures SoftSphere LLC ("CryptoRoute", "we", "us") applies to prevent the CryptoRoute website, interface, APIs and related services (together, the "Interface") from being used for money laundering, terrorist financing, sanctions evasion, or other financial crime.

CryptoRoute is a non-custodial software interface. We never hold, control, or have access to user funds or private keys, and we are not a broker, dealer, exchange, money services business, money transmitter, custodian, or financial advisor. Swaps are executed by independent third-party protocols and liquidity providers (including the NEAR Intents / 1Click protocol), wallet-to-wallet. This Policy reflects the controls we apply voluntarily and on a risk basis, appropriate to that non-custodial model.

1. Scope

This Policy applies to:

  • the swap interface — route discovery, quoting, and swap tracking for cross-chain crypto asset swaps; and
  • CryptoRoute Pay — hosted invoices, payment links, and the merchant API.

It applies to all users of the Interface and to all merchants onboarded to CryptoRoute Pay.

2. Risk-based approach

Because CryptoRoute never takes custody of funds and standard swaps do not require an account, our controls focus on the points we actually control: who can initiate a swap (jurisdiction), which addresses a swap touches (screening), where failed funds can go (refund-to-origin), and who can accept payments (merchant due diligence). Controls are applied on a risk basis and are reviewed as the product, its integrations, and the regulatory landscape evolve.

3. Sanctions compliance and restricted jurisdictions

We do not permit use of the Interface by persons or entities:

  • located in, ordinarily resident in, or organized under the laws of a country or region subject to comprehensive sanctions, or that we otherwise restrict; or
  • designated on sanctions lists administered by the United Nations, the United States (OFAC), the European Union, or the United Kingdom, or owned or controlled by such persons.

Enforcement at swap initiation:

  • Jurisdiction gate. Swap initiation is blocked from sanctioned and restricted regions using a trusted edge geolocation signal (not a client-supplied value). Where geolocation cannot be resolved, the gate can operate fail-closed — blocking the swap rather than allowing it through.
  • No circumvention. Accessing the Interface through tools or techniques that misrepresent your location in order to bypass these restrictions is prohibited and constitutes a breach of our Terms of Service.

4. Transaction screening (KYT)

Deposit and payout addresses involved in a swap are screened against sanctions and illicit-activity databases through a third-party blockchain-analytics (KYT) provider as part of swap processing. Where screening indicates an unacceptable risk — for example, association with sanctioned entities, darknet markets, stolen funds, or ransomware — we may refuse, block, or discontinue processing of the affected swap and restrict further use of the Interface.

5. Customer due diligence

  • Standard swaps. We do not perform identity KYC for standard swaps; screening is risk-based and operates at the address and jurisdiction level, as described above. This is consistent with our non-custodial model, in which we never receive or transmit user funds.
  • Enhanced measures. Where activity presents elevated risk, we may apply additional measures, including requesting information about the source of funds or the purpose of a transaction, refusing service, or terminating access.
  • CryptoRoute Pay merchants. Merchants must complete onboarding before accepting payments, providing their entity type, legal name, country, business address, and contact details. Applications are reviewed and approved individually, and merchant accounts may be rejected, suspended, or terminated where the business, its activity, or its payment patterns present unacceptable risk or breach this Policy.

6. Refunds return to origin

If a swap cannot complete, funds are returned only to the refund address on the origin network supplied when the swap was created — they are not redirected to new addresses, alternative networks, or third parties. For swaps started without an account, refund payouts additionally require the one-time claim secret issued at swap creation. This prevents the refund path from being used to obscure the origin or ownership of funds.

7. Prohibited activity

You may not use the Interface to engage in, facilitate, or conceal:

  • money laundering or the handling of proceeds of crime;
  • terrorist financing or the financing of weapons proliferation;
  • sanctions evasion;
  • fraud, theft, ransomware payments, or dealings with darknet markets; or
  • any other unlawful activity.

We may block, suspend, or terminate access at any time, with or without notice, where we believe use is unlawful, fraudulent, or in breach of this Policy or our Terms of Service.

8. Records and data

We retain the operational data generated by screening and swap processing in accordance with our Privacy Policy, and only for as long as necessary for the purposes described there, including compliance with legal obligations.

9. Cooperation with authorities

We cooperate with law enforcement, regulators, and other competent authorities on lawful requests relating to suspected financial crime, within the limits of the data a non-custodial interface actually holds.

10. Review of this Policy

This Policy is reviewed periodically and updated as our services, integrations, or applicable regulatory expectations change. Material changes take effect when posted, and we will update the "Last updated" date above.

11. Contact

Questions about this Policy, or reports of suspected misuse of the Interface: [email protected].

CryptoRoute is operated by SoftSphere LLC, registration no. 3982 LLC 2025 (Limited Liability Companies Act, Chapter 151 of the Revised Laws of Saint Vincent and the Grenadines, 2009), Suite 305, Griffith Corporate Centre, Kingstown, Saint Vincent and the Grenadines.

This document is a template provided for development purposes and is not legal advice. Have it reviewed and finalized by qualified legal counsel before production use.