As made clear in our Terms of Use, Swan is an online platform through which users are connected to licensed and regulated custodial partners such as Bakkt, BitGo, and Equity Trust. These custodians bear the responsibility of complying with money transmission laws in each state where they operate.
Bakkt - https://bakkt.com/disclosures
BitGo - https://www.bitgo.com/legal/disclosures/
Equity Trust - https://www.trustetc.com/terms-of-use/