| It's best to read the Google Terms of Service if you're not sure. But I think that link exchanges are not in breach of the TOS per se. However, Google will punish you for doing things like link exchanges through it's ranking (or possibly sandboxing) your site.
Keep in mind that they have tremendous computing power and brain power. If you do a reciprocal link with another site - Google will know about it. If the link exchange you go through has a distinquishing footprint (like a link back to the link exchange site) that's pretty easy for Google to figure out as well.
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