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AML and KYC Policy


The Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy of Luma Exchange (“the Company”) is designed to prevent and actively combat money laundering, terrorist financing, and other unlawful financial activities. The Company requires all officers, employees, and affiliates to strictly comply with these standards in the delivery of its services.

1. Purpose

Money laundering generally involves concealing the true source of illicit funds so that they appear to originate from legitimate activities. Terrorist financing may involve legitimate or illegitimate funds intended to support unlawful purposes. Luma Exchange is committed to identifying, mitigating, and preventing such activities across its operations.

2. Stages of Money Laundering

Money laundering typically occurs in three phases:

3. Employee Responsibilities

All employees with roles connected to customer interactions or financial transactions must understand and comply with AML and KYC laws applicable to their duties. Employees are required to report any suspicious activity immediately and act in full compliance with regulations at all times.

4. Legal Framework

The Company’s AML/KYC practices are aligned with international standards, including but not limited to:

5. AML and KYC Program

Luma Exchange maintains an ongoing compliance program that applies across all business units. This includes risk assessment, customer verification, continuous monitoring, and reporting of suspicious activity. Affiliates and subsidiaries of the Company are also bound by this policy.

6. Record Keeping

Identification documents and transaction records are maintained for the minimum period required under local law or longer where necessary for regulatory or legal purposes.

7. Training

New employees receive mandatory AML/KYC training during onboarding. Relevant staff are also required to complete annual refresher training, with targeted sessions provided for those in higher-risk positions.

8. Client Verification

Luma Exchange reserves the right to verify client identity at any time. Verification documents may include:

In certain cases (e.g., bank transfers), full verification is required prior to processing deposits or withdrawals.

9. Updating Client Information

Clients must notify Luma Exchange immediately of any changes in personal details (such as name, address, or phone number). Supporting documents may be required to validate updates, such as a phone service contract or identification showing consistency across records.

10. Document Authenticity

Clients are responsible for providing genuine documents. Luma Exchange reserves the right to confirm authenticity by contacting issuing authorities. Submitting falsified or altered documents is strictly prohibited and may result in account termination and reporting to authorities.

11. Client Cooperation

Failure to provide requested verification documents may result in temporary account suspension or permanent closure. Voluntary submission of documents is permitted, but in cases of regulatory requirement, submission becomes mandatory.

12. Compliance Commitment

Luma Exchange is fully committed to preventing its services from being used for illicit purposes. We work closely with regulators and law enforcement, and we continuously improve our internal procedures to maintain the highest compliance standards.