Anti-Financial Crime Policy
Last updated: January 2026. Bulls Change processes anonymous cryptocurrency swaps — including Bitcoin, Monero, USDT, Ethereum, XRP, Solana and 60+ other assets — without collecting user identity. This policy explains how we prevent financial crime without trapping deposited funds or demanding documents from legitimate users.
1. Our Position on Privacy and Responsible Operation
Bulls Change was built on a clear and defensible distinction: protecting legitimate users from unnecessary surveillance is not the same thing as enabling criminal activity. We do not require identity verification to swap any supported cryptocurrency pair. We do, however, maintain firm automated controls to prevent the platform from being used for money laundering, financing violence or processing funds derived from illegal activity.
Our operating model demonstrates that an anonymous, no-registration crypto exchange can function responsibly. Effective risk management does not require knowing who you are — it requires evaluating the risk profile of the transaction itself. That evaluation happens automatically before any swap is accepted into the system.
2. Prohibited Activities
The following uses of Bulls Change are strictly prohibited regardless of the asset pair selected or the amount involved:
- Processing funds derived from fraud, theft, extortion or other criminal offenses.
- Financing terrorism, political violence or any sanctioned militant organization.
- Circumventing economic sanctions imposed by the United Nations, European Union, OFAC or equivalent international bodies.
- Liquidating proceeds from ransomware attacks, darknet drug distribution or human trafficking operations.
- Executing structured micro-transactions designed to probe or evade our automated risk thresholds.
3. Transaction Limits as a Structural Risk Control
Rather than demanding identity documents, our primary structural defense against large-scale money laundering is enforced transaction sizing. These limits apply to every swap across all supported asset pairs:
- Minimum per order: $100 USD equivalent in any asset.
- Maximum per order: $282,100 USD equivalent in any asset.
These limits are enforced by the swap engine and apply uniformly to every user worldwide. They prevent the platform from being used for industrial-scale layering operations while fully accommodating the legitimate needs of privacy-conscious traders.
4. Pre-Trade Algorithmic Screening
"No AML holds" means we do not trap deposited funds pending document review. It does not mean we perform no checks at all. Our controls run before a swap order is accepted — not after your crypto has already arrived in the deposit address:
- Velocity monitoring: Our engine flags order patterns consistent with layering techniques — high-frequency, structured transactions across multiple pairs or amounts designed to obscure the origin of funds.
- Address screening: We maintain the capability to reject deposits from or to blockchain addresses identified as high-risk, including known ransomware wallets and sanctioned addresses, before the swap executes.
- Automatic refusal: Any transaction that triggers a severe risk threshold is automatically declined. No personal identity is requested or required for this process — the decision is made algorithmically on transaction characteristics alone.
5. User Attestation
By initiating a swap on Bulls Change, you confirm the following at the time of each and every transaction:
- The digital assets you are exchanging are legally owned and are not connected to criminal activity of any kind.
- You are not a sanctioned individual and are not acting on behalf of a sanctioned entity.
- Using a no-KYC cryptocurrency exchange does not violate the laws or regulations of your jurisdiction.
- You are transacting on your own behalf, not as an intermediary for undisclosed third parties.
6. Legal Cooperation
Bulls Change will comply with legally binding orders from recognized jurisdictions. However, because our architecture is designed around zero data collection, what we can provide in response to any lawful request is strictly limited to what we actually possess: order timestamps, blockchain addresses involved in specific transactions and session metadata. We cannot provide names, email addresses, IP address histories or user profiles because our system was architected never to collect them.
7. Privacy Is Not a Legal Shield
Swapping crypto anonymously on Bulls Change provides robust protection against corporate data harvesting and unnecessary personal surveillance. Using our platform does not provide immunity from prosecution under applicable law. Users who exploit our routing infrastructure to commit financial crimes remain fully liable under the laws of their jurisdiction, regardless of the privacy protections the platform provides.
8. Policy Updates
Our risk controls evolve as the threat landscape changes. We update our algorithmic defenses and this policy periodically to reflect current standards. No mandatory KYC will ever be introduced as a result of these updates — our zero-collection architecture is a core platform commitment, not a feature subject to modification or removal.
9. Contact
Questions about our risk controls or suspected misuse of the platform can be directed to support@bulls-change.com.