Why we have this policy
Swaps on BayChange are executed by a decentralised protocol (the “Protocol”), and we never hold customer funds. Even so, we make the Service available and earn a fee from it. So we take reasonable, risk-based measures to stop it from being used for money laundering, terrorist financing or sanctions evasion.
This policy is part of our Terms of Use. Our measures are designed to meet [applicable AML and sanctions laws and the requirements of our regulator, if any].
Who can't use BayChange
You may not use BayChange if you are:
- a person or entity named on a sanctions list, or owned or controlled by one;
- located in, resident in or organised under the laws of a restricted jurisdiction;
- acting on behalf of, or for the benefit of, anyone above.
Using a VPN, proxy or any other tool to hide where you are is a breach of our Terms. If we detect it, we may refuse your orders.
Restricted jurisdictions
We don't provide the Service to anyone located in, ordinarily resident in, or organised under the laws of the following countries and regions:
List of restricted jurisdictions — to be confirmed by legal counsel. It will include at least every country and region under comprehensive sanctions in the regimes we apply.
We block access from these places based on IP location. The list can change at short notice when sanctions change; the version on this page applies.
What we check before you send
When you create an order, and before we show you a deposit address, we check both addresses you entered — the payout address and the refund address — against:
- official sanctions lists that include digital asset addresses, starting with the US Treasury's OFAC Specially Designated Nationals (SDN) List, plus [other lists that apply, e.g. UN, EU, UK]. We refresh our copy at least [daily];
- blocklists of stablecoin issuers, such as addresses frozen by Tether for USDT;
- [risk signals from third-party screening providers].
After your deposit arrives, the address you sent from may also be screened — by the Protocol and, where available, by us.
The checks are automatic and usually take a few seconds. Sanctions lists are not complete, and passing our checks doesn't mean that funds are clean. You remain responsible for the lawful origin of your funds.
What happens if an address matches
Before you send — the usual case
We don't create the order and don't show a deposit address. You'll see a message that we can't process an order with this address. No money has moved, so nothing is held or lost. We may not be able to tell you which list matched. We keep a record of the check.
If you think it's a mistake
Write to [[email protected]] with the address. We review requests within [3 business days]. If the match was a false positive, we'll allow the address again. We can't allow an address that is on an official sanctions list.
After you've sent funds
A match can also appear after a deposit — for example, if the address you sent from is flagged, or a list is updated while your swap is in progress. Then what happens to the funds is decided by the Protocol, the stablecoin issuer or the authorities, not by us. Usually the Protocol rejects the deposit and returns it to your refund address. Where the law requires, funds may instead be blocked and released only through a legal process.
Checks by protocols and stablecoin issuers
Other parties run their own checks, independently of ours:
- The Protocol. Participants authorised by the protocol can screen deposits and reject them. A rejected deposit is returned to the refund address of your order, minus network fees.
- Other routes (only if your order uses one). The operators of those protocols and their providers screen transactions and may delay, block or freeze them — sometimes for a long time — and resolve them through their own processes.
- Stablecoin issuers, such as Tether and Circle, can freeze tokens at any address. Frozen tokens can't move until the issuer releases them.
We can't see their criteria or override their decisions. If your funds are affected, we'll share what we know and tell you who to contact.
Funds we don't accept
Don't use BayChange for funds that come from, or are meant for:
- fraud, scams, theft, hacks or exploits;
- ransomware, extortion or darknet markets;
- terrorist financing or sanctions evasion;
- child sexual abuse material, drug or human trafficking, or any other crime;
- mixers, tumblers or other services used to hide where funds came from.
Pausing routes after hacks
We watch for major security incidents. After a large hack or exploit, we may pause an asset, network or route so that stolen funds can't be swapped through BayChange. We may also pause a route if a Protocol is attacked or stops working normally.
Orders already in progress are completed or refunded by the Protocol.
If you are a victim of theft or fraud
If your funds were stolen and you believe they passed through BayChange, write to [[email protected]] with the transaction hashes, addresses, date and time, and a police or incident report number if you have one.
We'll check our records, provide them to law enforcement on request, and can alert the Protocol. We can't return funds ourselves.
Records we keep
For each order, we keep the order details and the results of screening checks for [5 years]. Details are in our Privacy Policy.
What we won't do
- We won't give advice or help on how to get around sanctions, screening, geographic restrictions, reporting duties, or another platform's limits. Our support team won't answer such requests, and making them may lead us to refuse your orders.
- We don't describe BayChange as anonymous or untraceable, because it isn't: blockchain transactions are public, and we keep records as described above.
Changes and contact
We review this policy regularly and whenever sanctions or the law change. The current version is always on this page.
Questions about this policy or a screening result: [[email protected]].
