ChangeNOW flagged you
for AML review? We resolve it.

ChangeNOW holds swaps when their AML Bot flags source addresses, requiring KYC before releasing the funds — with no account creation option. ChangeNOW uses a dual-screening system: AML Bot for pre-screening and Crystal Blockchain for deeper analysis. This means even low-risk flags can trigger a hold, because the two systems have different sensitivity levels and either one can block a swap. This background matters because it shapes how ChangeNOW handles compliance — and how we approach resolving your case.

The compliance framework: ChangeNOW operates under Cayman Islands AML Regulations 2020, overseen by Cayman Islands Monetary Authority (CIMA). Their compliance infrastructure uses AML Bot + Crystal Blockchain for blockchain analytics and internal for identity verification. ChangeNOW is known for custody-free swaps with no maximum limits, serving privacy-conscious users wanting instant swaps — and their compliance team is calibrated to flag deviations from typical user behavior in that segment.

What triggers aml review on ChangeNOW:

• Risk score escalation: When your ChangeNOW account's cumulative risk score exceeds a threshold (based on transaction patterns, counterparties, and volume), ChangeNOW triggers a formal AML review under Cayman Islands AML Regulations 2020.
• Suspicious Activity Report (SAR): If ChangeNOW's compliance team files a SAR with Cayman Islands Monetary Authority (CIMA), your account enters an AML review that cannot be resolved through standard support.
• Regulatory inquiry: Cayman Islands Monetary Authority (CIMA) may request an AML review of your account as part of a broader investigation — ChangeNOW must comply and cannot disclose the reason to you.
• Periodic compliance check: ChangeNOW conducts periodic AML reviews on accounts above certain thresholds — even without suspicious activity, high-value accounts are reviewed annually.

Real case — dual-screening system: A user swapped 2 ETH to BTC on ChangeNOW. AML Bot passed the transaction, but Crystal Blockchain flagged it as 'medium risk' because the source ETH address had interacted with a DeFi protocol that was later associated with a hack. ChangeNOW held the swap output and demanded KYC. The user had never created an account and had no support history. We documented the DeFi interaction as legitimate (the protocol was not hacked at the time of interaction) and ChangeNOW released the funds in 14 days.

What ChangeNOW requires to resolve this: Depending on the trigger, ChangeNOW may ask for government-issued photo ID (verified through internal), proof of address (utility bill or bank statement within 3 months), source-of-funds documentation (exchange statements, bank records, payslips, tax returns, or business documents), detailed transaction explanations with on-chain evidence, and in some cases a video verification interview. The challenge: ChangeNOW rarely tells you which specific trigger caused the aml review, so you're guessing at what documentation to provide — and each rejected submission makes the next one harder.

Our approach is specific to ChangeNOW: ChangeNOW's dual-screening creates ambiguity about which system flagged the transaction. We request the specific risk assessment from both AML Bot and Crystal Blockchain, identify the flagging source, and prepare a rebuttal targeted at that specific system's methodology. Crystal Blockchain's risk scoring is more opaque than Chainalysis, which requires more detailed on-chain evidence.

AML Review on ChangeNOW — our strategy: We prepare a comprehensive AML compliance package: transaction tracing, source-of-funds documentation, explanation of trading patterns, and a legal cover letter demonstrating your compliance with applicable AML regulations in the platform's jurisdiction.

The submission that matters: Instead of submitting through ChangeNOW's standard support channels (where you'll get automated responses or generic template replies), we prepare a professional legal submission — a structured compliance package with a cover letter from a Swiss law firm citing Cayman Islands Monetary Authority (CIMA) obligations and Cayman Islands AML Regulations 2020. ChangeNOW's compliance team processes legal submissions differently from regular user tickets — they're assigned to senior compliance officers, not support agents, and they bypass the automated response loop that delays most cases by weeks.

When standard compliance isn't enough: Some situations fall outside the normal compliance flow — inherited crypto holdings, accounts registered under another person's name, unprovable source of funds through conventional documentation, or cross-jurisdictional complications where your residence, the exchange's jurisdiction, and the fiat banking path all differ. If that sounds like your case, our complex cases practice handles scenarios that other firms decline.

Further reading: our guide on crypto AML laws across Europe covers the documentation and legal strategy in more depth.