Wire payments and their possible delays - Complexities of EU AML Laws Explained

Effective Date: Sep 1st, 2025

Understanding AML Requirements at SWAPD

As a Canadian-registered entity, SWAPD (operated by VEYYO Limited Partnership, Canada) is legally bound by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the oversight of FINTRAC (Financial Transactions and Reports Analysis Centre of Canada).

These laws are designed to prevent money laundering, terrorist financing, and other financial crimes. They require financial institutions and payment processors — and by extension, SWAPD as Merchant of Record — to perform strict customer due diligence (CDD) and Know Your Customer (KYC) procedures.

This means:

  • Buyers and subcontractors may be asked to provide additional identification documents such as passports, utility bills, or proof of income.
  • Some transactions, especially cross-border payments, may be delayed due to enhanced verification by banks, processors, or regulators.
  • Transactions involving certain jurisdictions may be flagged for extra scrutiny or blocked altogether.

High-Risk Countries

The following countries are currently designated as high-risk jurisdictions by the Financial Action Task Force (FATF) or subject to enhanced monitoring under Canadian AML/CTF regulations.

High-Risk Jurisdiction Notes
Afghanistan Ongoing monitoring since 2016
Barbados Added 2020
Burkina Faso Added 2022
Cambodia Added 2020
Cayman Islands Added 2022
Democratic Republic of the Congo Added 2023
DPRK (North Korea) Ongoing since 2016
Gibraltar Added 2023
Haiti Added 2022
Iran Ongoing since 2016
Jamaica Added 2020
Jordan Added 2022
Mali Added 2022
Morocco Added 2022
Mozambique Added 2023
Myanmar Added 2020
Panama Added 2020
Philippines Added 2022
Senegal Added 2022
South Sudan Added 2022
Syria Ongoing since 2016
Tanzania Added 2023
Trinidad and Tobago Added 2018
Uganda Ongoing since 2016
United Arab Emirates Added 2023
Vanuatu Ongoing since 2016
Yemen Ongoing since 2016

Any incoming or outgoing payments linked to these jurisdictions may experience significant delays, additional documentation requests, or outright rejection. SWAPD has no control over these regulatory decisions.


What This Means for SWAPD Users

  • Expect Possible Delays – Cross-border transactions involving flagged jurisdictions may take weeks longer to clear.
  • Be Prepared to Provide Documentation – Banks and processors may request proof of identity, source of funds, or transaction purpose before releasing payments.
  • Non-Negotiable Compliance – SWAPD is legally required to follow AML/CTF laws. Failure to comply will result in cancelled or frozen transactions.

Binding Obligation for Subcontractors

By participating in transactions on SWAPD, subcontractors expressly acknowledge and agree that:

  • Payouts may be withheld or delayed until all AML/CTF checks are cleared by banks, processors, or regulators.
  • SWAPD (VEYYO LP) is under no obligation to release funds until such clearance is complete.
  • Any additional costs, documentation requests, or delays caused by subcontractor-related AML/CTF reviews are the subcontractor’s sole responsibility.

Disclaimer

SWAPD (VEYYO LP, Canada) complies fully with Canadian AML/CTF regulations and global FATF guidelines. While every effort is made to process payments quickly, SWAPD is not liable for delays, freezes, rejections, or losses caused by banks, intermediaries, regulators, or third-party financial institutions once funds have been transmitted into the international banking system.