AML policy

Crypto Train is a comparison and routing tool. It never takes custody of funds at any point. Your browser pays the exchange provider's deposit address directly, and that provider pays your destination address directly. This service is not a party to either transfer, holds no balances, operates no wallets on your behalf, and cannot move, freeze, refund or recover anything.

That is a description of the architecture, not a disclaimer about it. It is why the obligations that attach to a custodian do not attach here, and it is also why the controls described below are the ones that are actually possible for us to operate.

Before a Bitcoin destination address is used, it is checked against the US Treasury's Specially Designated Nationals list, which OFAC publishes openly. A payout to a listed address is overwhelmingly likely to be frozen rather than delivered, and the interface says so before anything is signed.

The method matters as much as the fact. We fetch the published list and match against it on our own server. We do not use a screening vendor, because a screening API answers the question by receiving the address — which is precisely the disclosure this service exists to avoid. The list comes to us; your address never leaves.

The list is refreshed several times a day. Matching is verified in both directions: known-listed addresses are asserted to be found and ordinary addresses asserted to be clear, because a matcher that silently finds nothing is worse than no matcher at all.

We do not perform blockchain forensics. We cannot tell you whether funds passed through a mixer, how many transactions they are from a hacked exchange, or what risk score a commercial analytics firm would assign them. That analysis requires clustering across entire chain histories, sold by firms whose business model is the surveillance of exactly the people this service is built for. We do not buy it, and we would have to send them your address in order to use it.

For Monero there is additionally nothing to screen. There is no public ledger to read. Six XMR addresses appear on the sanctions list and that is the entire extent of what anybody can say about a Monero address from outside.

What we publish instead is counterparty risk: how often each provider actually answers, and what each provider's own terms permit it to do with funds it holds, quoted exactly.

We do not collect identity documents, and we do not operate accounts. There is no sign-up, no email address required, and no customer file. This is deliberate and it is stated on every page that touches the subject.

Each exchange provider applies its own identity and anti-money-laundering procedures to the funds it receives, because it is the party that receives them. Several of the providers compared here reserve the right to request identification part-way through a transfer, and some reserve the right to withhold funds until it is supplied. We do not hide that: it is published provider by provider, in their own words, with the dates we read them.

Creating an identity store here would not add a control. It would duplicate, at the party handling no funds, information already held by the party handling them — and would create a second collection of exactly the data that makes a breach or a demand for records damaging. The privacy page lists everything that is in fact recorded, including the parts that do not flatter us.

This service may not be used to evade sanctions, launder the proceeds of crime, or finance terrorism. We will not assist with any attempt to defeat a provider's screening, and sanctions screening on this site is not optional and will not be removed on request.

We reserve the right to decline to route a transfer. Because we hold no funds, declining means refusing to assist — it never means holding your money, which we could not do in any case.

If you believe this service has been used in connection with a crime, or you have identified an address that should be screened and is not, use the Contact us button on any page. You will be given a reference. We hold no customer records to produce, which is a limit on what any request to us can obtain rather than a position about such requests.

You can also write to compliance@crypto-train.com, which is read every day. It is the right route for a provider’s compliance team or for anyone reporting something found outside this site; it issues no reference, so the button above remains the better one if you are here as a customer.

Requests that concern a particular exchange should go to the provider that performed it. They hold the deposit, the payout and the record; we hold a comparison of prices. The provider is named on screen for every exchange, and the terms say who holds funds at each step.