Last updated: May 2026
Our role in the AML chain
SwiftSend is an independent broker. Regulated client due diligence ("KYC"), source-of-funds verification, sanctions screening, and ongoing monitoring is carried out by the supplier — a firm authorised in its own jurisdiction. That supplier carries the regulated responsibility for AML compliance on the transaction it executes.
SwiftSend's role is the introduction and supplier coordination — the brokerage layer that sits above the regulated activity. See our Brokerage Disclosure for the full position statement.
What we still do
Even though the regulated KYC happens at the supplier, we operate to a baseline standard:
- We collect sufficient information at the brief stage to introduce you appropriately.
- We screen for obvious red flags before passing introductions to suppliers.
- We will not knowingly introduce a client to a supplier where we believe the underlying transaction is unlawful, fraudulent, or sanctioned.
- We cooperate with lawful information requests from law enforcement and regulators.
- We retain records of introductions and communications for a reasonable period.
What suppliers will do
Suppliers conduct full client due diligence before executing any payment. This typically includes:
- Identity verification (passport, driving licence, proof of address).
- For businesses: company information, ultimate beneficial owner identification.
- Source of funds and, for higher-value transactions, source of wealth declarations.
- Sanctions and politically exposed persons (PEP) screening.
- Ongoing transaction monitoring for unusual activity.
If a supplier requests additional documentation from you, this is required by their regulatory obligations. SwiftSend will help facilitate but cannot waive a supplier's compliance requirements.
Sanctions
SwiftSend will not introduce clients in connection with transactions that breach UK sanctions, EU sanctions, US OFAC sanctions, or UN sanctions applicable to the relevant jurisdiction.
This includes — but is not limited to — transactions involving:
- Sanctioned individuals, entities, or vessels on consolidated sanctions lists.
- Sanctioned jurisdictions (the lists evolve; current UK consolidated list is published by HM Treasury).
- Activities indirectly facilitating sanctioned parties.
We reserve the right to decline any introduction at our sole discretion on sanctions grounds, with or without explanation.
Source of funds / source of wealth
Where the supplier requires source-of-funds or source-of-wealth declarations (typically for higher-value or higher-risk transactions), the documentation requirements are set by the supplier. Common documentation includes: bank statements, salary records, sale-of-asset documents, inheritance documents, gift declarations. SwiftSend will let you know what to expect at introduction but cannot reduce the supplier's documentary requirements.
Reporting to authorities
SwiftSend will report concerns of suspected money laundering, terrorist financing, fraud, tax evasion, sanctions breach, or other unlawful conduct to the appropriate UK authority where we have grounds to do so. This includes — but is not limited to — reporting to:
- The National Crime Agency (NCA) — Suspicious Activity Reports (SARs) under the Proceeds of Crime Act 2002 and the Terrorism Act 2000.
- HM Revenue & Customs (HMRC) — for matters relating to tax, customs, or HMRC's anti-money-laundering supervision remit.
- The Financial Conduct Authority (FCA) — for concerns relating to regulated firms within our supplier network.
- HM Treasury (Office of Financial Sanctions Implementation) — for sanctions-related concerns.
- UK police and other law enforcement bodies — where a criminal matter is suspected.
- Equivalent authorities in other jurisdictions — where the matter has cross-border relevance and we have a lawful basis to report.
Where the law requires it, we will make these reports without notifying the client ("tipping off" rules under UK financial crime law). This applies even where the client believes their activity is lawful — the obligation to file a report sits with us based on the indicators, not the client's intent.
Cooperation with regulators and law enforcement
SwiftSend cooperates fully with lawful requests for information from UK and international regulators, tax authorities, law enforcement, and courts. This includes — but is not limited to:
- HM Revenue & Customs (HMRC)
- The National Crime Agency (NCA)
- The Financial Conduct Authority (FCA)
- The Information Commissioner's Office (ICO)
- HM Treasury / OFSI (sanctions)
- UK police forces and Serious Fraud Office
- Foreign equivalents where applicable and lawful
We will respond to court orders, production orders, and lawful regulatory requests. We may share information that includes your personal data where compelled to do so by law.
What this means for you
By using SwiftSend's broker service, you acknowledge that:
- We may report to UK authorities where we have grounds.
- We may do so without notifying you in advance.
- We may freeze further introductions where a report has been filed and we are awaiting authority response.
- This applies whether or not the supplier you transact with is FCA-authorised — our reporting obligations as a broker sit independently of the supplier's regulatory status.
This is not unusual for any business operating in financial services in the UK. We name it openly so there are no surprises.
Right to decline
SwiftSend reserves the right to decline any introduction request, to refuse onward service, and to terminate a client relationship at our sole discretion. Reasons include — but are not limited to — AML/CTF concerns, sanctions risk, fraud indicators, or where the request falls outside the criteria of our supplier network.
Questions
Email hello@swiftsend.world with subject "AML / Compliance".