Sunset Swap Exchange with weak or absent KYC
cluster sunset-swap · Panama
· 2 known address(es)
· ETH, OPTIMISM
Intrinsic severity6of 10
Default bandmedium
Attributionmoderate0.75 confidence
On-chain partyoperator
Attribution quality
| Level | moderate |
| Source | synthetic |
| Basis | corroborated open-source intelligence |
Operator versus beneficiary
| Custody model | custodial |
| On-chain party | operator |
| Beneficiary on-chain | no |
Known addresses
0x3239256ce8b4df...0xe819abad0bb6f7...
Service risk profile
AML posture0of 100, poor
KYC strictnessweak
from $10,000
LicenceunlicensedMiCA not authorised
Jurisdiction risk5of 10
Effectively unsupervised; treat as a laundering route, not an endpoint.
Regulatory file
| Legal name | Sunset Swap |
| Founded | 2013 |
| Incorporated in | Panama (PA) |
| Operational hubs | AF, PA |
| Regulator | no identified regulator |
| Licence reference | none |
| Licence evidence | none |
| FATF grey list | yes |
| Offshore secrecy | yes |
Controls
| Custody model | custodial |
| KYC rigour | weak |
| Transaction monitoring | absent |
| Sanctions screening | no |
| Travel Rule | absent |
| Source-of-funds checks | no |
Posture deductions
| Finding | Points |
|---|---|
| No licence or registration in any supervisory regime | -30 |
| Identity checks are partial or easily circumvented | -18 |
| Customers and counterparties are not screened against sanctions lists | -15 |
| Incorporated in an offshore secrecy jurisdiction | -12 |
| Incorporated in a FATF grey-listed jurisdiction | -10 |
| Not authorised under MiCA despite operating in scope of it | -8 |
| Source of funds is not evidenced for large deposits | -8 |