Institutional policies | Swapo Finance

This translation is provided for convenience. The Portuguese version is the official text and prevails in case of any discrepancy.

About the policies

BCB Resolution No. 520/2025 (art. 52, § 1, III) requires the virtual asset service provider company to disclose its organizational policies. This page gathers the public versions of the documents that are part of Swapo's authorization request as a virtual asset service provider company, in the intermediary category.

The authorization request is under review at the Central Bank of Brazil and the authorization has not been granted yet. Publishing these policies does not represent BCB approval or certification that each control has already been audited.

Each public version summarizes the internal document and omits personal data, monitoring parameters and technical security details.

Services and client relationship

Description of virtual asset services. What Swapo does in the intermediary category: order flow, responsibilities, limits, price formation, absence of custody, transfers and activities it does not provide. Document dated September 21, 2026.
Commercial and Client Relationship Policy. Principles and rules for Swapo's offering of services, client information, pricing, service, complaint handling and advertising. Document dated September 21, 2026.
Custody model and operational wallets. Swapo declares that it does not provide custody of virtual assets. Assets pass through Swapo's transactional wallets transitorily and automatically, for less than 24 hours, and continue on to the wallet indicated by the client or to the destination of the transaction. Document dated September 21, 2026.

Anti-money laundering and identification

Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CFT). Principles, governance and procedures that Swapo must adopt to prevent, detect and report money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction, with attention to the risks of virtual assets. Document dated October 14, 2026.
Know Your Customer (KYC) Policy. How Swapo must identify, verify, risk-classify and monitor its clients, which documents may be requested, and when the relationship may be refused or terminated. Document dated October 14, 2026.
Know Your Business (KYB) Policy. How Swapo must identify, verify and monitor corporate clients, partners and suppliers, including the ultimate beneficial owner, and when it may refuse or terminate the relationship. Document dated October 14, 2026.
Know Your Transaction (KYT) Policy. How Swapo must continuously monitor clients' transactions, assess their consistency with each client's profile and handle atypical or suspicious operations. Document dated September 21, 2026.
Know Your Wallet (KYW) Policy. How Swapo must identify the virtual asset wallets used by clients, confirm their ownership, assess their risk and handle wallets that are not accepted. Document dated October 14, 2026.
Travel Rule Policy. How Swapo must collect, verify, transmit and keep the originator and beneficiary information in virtual asset transfers, including with other providers and self-custodied wallets. Document dated September 21, 2026.
Procedures for Reporting Suspicious Transactions and Specific Transactions to COAF. How Swapo must identify, analyze and report to COAF (Brazil's Financial Intelligence Unit) suspicious transactions and transactions subject to mandatory reporting, with confidentiality and a record of each decision. Document dated October 14, 2026.

Governance, risks and controls

Internal Controls, Compliance and Operational Governance Policy. Defines Swapo's internal controls, compliance and governance structure: responsible officers, committees, the three-lines model, the risk and control matrix, effectiveness testing and the handling of nonconformities. Document dated September 21, 2026.
Regulatory Compliance Program. Describes Swapo's compliance structure: Senior Management, the Responsible Officer and the Compliance Committee, regulatory mapping, testing, handling of non-compliance, training and whistleblowing channels. Document dated September 21, 2026.
Risk Management Policy. Establishes Swapo's principles, governance and risk categories, and how to identify, assess, monitor and mitigate operational, technological, regulatory, AML/CFT, reputational and third-party risks. Document dated September 21, 2026.
Risk Policy. Sets out the risks associated with virtual asset services, the user's responsibilities, the controls Swapo may adopt and the minimum incident response flow. Document dated September 21, 2026.
Liquidity Management Policy. Defines how Swapo must maintain liquidity to meet its obligations, including in adverse scenarios: sources and uses of funds, segregation, liquidity providers, stress tests and contingency plans. Document dated September 21, 2026.
Asset Segregation Policy. Establishes the legal, accounting, operational and asset separation between Swapo's funds and the funds and assets of clients, with rules for accounts, wallets, records, access and insolvency cases. Document dated September 21, 2026.

Information security and continuity

Information Security Policy. Swapo's guidelines for protecting the confidentiality, integrity and availability of information, including the general lines of the cyber security policy and the protection of personal data. Document dated September 21, 2026.
Cryptographic key management and recovery. Principles that Swapo adopts to generate, store, use, recover and dispose of the cryptographic keys of its operational wallets, with segregation of duties, multiple approvals, auditable records and recovery tests. Document dated September 21, 2026.
Business Continuity Plan. How Swapo prepares to keep its critical activities running and to resume operations in an orderly way after system failures, cyberattacks, third-party failures or unavailability of its headquarters, with notice to clients when applicable. Document dated September 21, 2026.

Ethics, conflicts of interest and suppliers

Code of Ethics and Conduct. Principles and rules of conduct for Swapo's administrators, employees and partners, with rules on anti-corruption, gifts, conflicts of interest, confidentiality, relationships and the whistleblowing channel. Document dated September 21, 2026.
Policy on the Identification, Prevention and Mitigation of Conflicts of Interest. How Swapo must identify, prevent, record and mitigate actual, potential or apparent conflicts of interest, and inform the client when a conflict may affect the transaction. Document dated September 21, 2026.
Policy on Relationships, Contracting and Contact with Liquidity Providers. Criteria for selecting, assessing, contracting, monitoring and offboarding Swapo's liquidity providers, with rules on communication, settlement and mitigation of conflicts of interest. Document dated September 21, 2026.