AML Policy

1. Introduction

Ghost Exchange is committed to preventing the use of its platform for money laundering, terrorist financing, or any other illicit activity. This Anti-Money Laundering (AML) Policy outlines the measures we take to detect, prevent, and report suspicious activities while maintaining the privacy of our legitimate users.

2. Our Approach

Ghost Exchange operates as a non-custodial, privacy-focused exchange with Monero (XMR) at its core. While we do not collect personal identification information, we employ automated systems to monitor transactions for patterns indicative of illicit activity. Our approach balances user privacy with our responsibility to prevent misuse of the platform.

3. Transaction Monitoring

We utilize automated risk scoring and monitoring systems that flag:

• — Unusually large transactions that exceed established thresholds
• — Rapid, repeated transactions in short time windows
• — Transactions involving addresses flagged by blockchain intelligence services
• — Patterns consistent with structuring or layering techniques

4. Blockchain Analysis

For non-privacy coins (BTC, ETH, etc.), we may use blockchain analytics tools to screen incoming and outgoing addresses against known blacklists, including addresses associated with ransomware, darknet markets, sanctioned entities, and stolen funds. This screening occurs at the transaction level without collecting user identity data.

5. Risk-Based Approach

We employ a risk-based approach to AML compliance. Transactions are categorized by risk level based on factors including transaction size, frequency, source chain, and destination patterns. Low-risk transactions are processed automatically. Elevated-risk transactions may be subject to additional review or delay.

6. Sanctions Compliance

Ghost Exchange screens applicable blockchain addresses against international sanctions lists including those maintained by OFAC, the EU, and the UN. Transactions involving sanctioned addresses will be blocked. We regularly update our screening databases to reflect new designations.

7. Suspicious Activity

If our systems detect activity that appears to be related to money laundering, terrorist financing, or other financial crimes, we reserve the right to:

• — Delay or halt the transaction pending review
• — Block the transaction and refund to the originating address
• — Report suspicious activity to relevant authorities as required by law

8. Record Keeping

In cases where transactions are flagged for review or blocked due to compliance concerns, we may retain limited transaction data (wallet addresses, amounts, timestamps) for the period required by applicable regulations. This data is stored in encrypted form and is not used for any purpose other than compliance.

9. Staff Training

Our compliance team receives regular training on AML best practices, emerging money laundering techniques, and regulatory updates. All team members with access to transaction data are subject to confidentiality obligations.

10. Cooperation with Authorities

Ghost Exchange will cooperate with law enforcement agencies when presented with valid legal orders. We comply with applicable legal requirements while protecting user privacy to the maximum extent permitted by law.

11. Policy Updates

This AML Policy is reviewed and updated regularly to reflect changes in regulations, risk landscape, and best practices. Updates will be posted on this page with a revised date.

12. Contact

For questions or concerns about our AML practices, please contact us at our support page.