Regulatory Compliance & AML/Sanctions Framework

1. Statutory Regulatory Classification

Regulatory Disclaimer: Arrogator.com is a decentralized software routing interface and non-custodial information directory. Arrogator does not hold, custody, possess, or control user funds, private keys, or digital assets at any time. All cryptocurrency exchange, swap, and bridging transactions initiated through this interface are facilitated and settled exclusively by independent third-party non-custodial liquidity protocols, including ChangeNOW (CHPlugin Service). Arrogator does not operate as a financial institution, centralized custodian, broker-dealer, money services business (MSB), or investment adviser.

2. Anti-Money Laundering (AML) & Sanctions Framework

Compliance & Sanctions Notice: In accordance with global Anti-Money Laundering (AML) standards and OFAC international sanctions frameworks, transaction routing through the ChangeNOW protocol employs automated on-chain risk-scoring algorithms. High-risk transactions associated with sanctioned entities, mixing services, darknet marketplaces, or fraudulent activities may be temporarily halted for standard identity verification (KYC). Access is strictly prohibited for persons or entities located in or residents of sanctioned territories, including Cuba, Iran, North Korea, Crimea, Sudan, Syria, and any other jurisdiction subject to comprehensive international embargoes.

3. FinCEN and International Regulatory Alignment

Under guidance issued by the Financial Crimes Enforcement Network (FinCEN) and international regulatory bodies, providers of unhosted software interfaces that do not accept, hold, or transmit funds on behalf of users are not classified as Money Services Businesses (MSBs) or money transmitters.

4. Automated Risk-Scoring and KYC Triggers

Transactions initiated through the embedded ChangeNOW protocol are subject to automated on-chain risk analysis. Transactions originating from addresses linked to sanctioned entities, darknet marketplaces, ransomware operations, or mixer protocols will be halted by the protocol compliance mechanisms.