Legal · AML policy
Last updated: March 2026
Anti-Money Laundering and Risk Policy
This policy describes Terce's approach to anti-money laundering (AML) risk. Terce is a non-custodial cryptocurrency exchange service. We do not take custody of funds, hold balances, or act as a financial institution. We do not collect identity information and do not operate a Know Your Customer (KYC) program.
This policy reflects the nature of the service. Non-custodial exchange operators occupy a different position in the financial system than custodial exchanges, banks, or money services businesses. We do not have the ability to freeze funds, reverse transactions, or prevent users from moving assets they control. We route conversion transactions through established infrastructure and have no ongoing relationship with users after a transaction completes.
Terce may not be used to exchange proceeds of criminal activity including but not limited to fraud, theft, ransomware, narcotics trafficking, or human trafficking. Terce may not be used to circumvent lawful financial sanctions administered by OFAC or equivalent authorities. Terce may not be used to fund terrorism, weapons proliferation, or other activities prohibited under applicable US law.
By initiating an exchange, you represent that the funds you are exchanging are lawfully owned, not proceeds of criminal activity, and not subject to sanctions restrictions.
We operate the following controls consistent with our non-custodial model:
Blockchain analytics. We use third-party blockchain analytics infrastructure to screen transaction inputs against known risk indicators including addresses associated with sanctioned entities, darknet markets, ransomware operations, and other high-risk activity. Transactions flagged by this screening may be delayed or declined.
Sanctions screening. We screen destination addresses against OFAC's Specially Designated Nationals (SDN) list and other applicable sanctions lists. Transactions involving sanctioned addresses will not be processed.
Threshold monitoring. We monitor for patterns consistent with structuring or other evasion techniques. Unusual patterns may result in additional scrutiny or service refusal.
We reserve the right to decline any exchange without explanation where we assess elevated risk, regardless of whether a specific prohibited category applies.
We retain transaction records — including blockchain addresses, asset types, amounts, and timestamps — for a minimum of five years. These records may be provided to law enforcement or regulatory authorities in response to lawful requests.
We do not operate a KYC program. We do not collect names, government-issued identification, or other personally identifiable information in the ordinary course of business. Our AML risk model is blockchain-based rather than identity-based, consistent with our non-custodial operating model.
Terce will cooperate with lawful requests from law enforcement and regulatory authorities including requests for transaction records, blocking of specific addresses, and other legally required actions. We will respond to lawful process directed at information within our control.
This policy may be updated from time to time. Material changes will be noted by updating the "Last updated" date.