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Responsible Use Policy

Last updated: March 2026

Purpose

This Responsible Use Policy outlines the expectations for using Lumo B2B Platform in a manner that is ethical, legal, and compliant with applicable regulations.

Compliance Requirements

Know Your Customer (KYC)

As a Lumo B2B client, you must:

  • Implement appropriate KYC procedures for your end users
  • Verify the identity of users before enabling crypto transactions
  • Maintain records as required by applicable regulations

Anti-Money Laundering (AML)

You must NOT:

  • Process funds known or suspected to be derived from illegal activities
  • Facilitate transactions for sanctioned entities or individuals
  • Structure transactions to avoid reporting thresholds

You MUST:

  • Report suspicious activities to appropriate authorities
  • Cooperate with law enforcement requests
  • Maintain transaction records for required retention periods

Sanctions Compliance

You are prohibited from:

  • Processing transactions involving OFAC-sanctioned countries
  • Facilitating transactions for sanctioned individuals or entities
  • Circumventing sanctions through intermediaries

Transaction Monitoring

Our Monitoring

We perform automated monitoring including:

  • AML screening of incoming transactions
  • Blockchain analysis for high-risk indicators
  • Pattern detection for suspicious behavior

Your Obligations

You should implement:

  • Transaction velocity monitoring
  • Large transaction alerts
  • User behavior analysis

Prohibited Activities

The following uses are strictly prohibited:

  • Money laundering or terrorist financing
  • Processing funds from illegal gambling operations
  • Facilitating ransomware payments
  • Tax evasion schemes
  • Fraud or scams
  • Processing for dark web marketplaces
  • Any activity that violates applicable laws

High-Risk Indicators

Transactions may be flagged for review if they exhibit:

  • Connections to high-risk jurisdictions
  • Mixing service usage
  • Rapid movement through multiple wallets
  • Unusually large or frequent transactions
  • Known illicit wallet addresses

Blocked Transactions

If a transaction is blocked due to AML screening:

  1. You will receive a deposit.aml_failed webhook
  2. Funds are held pending review
  3. Contact support for resolution process
  4. Additional documentation may be required

Reporting

Suspicious Activity

If you identify suspicious activity:

  1. Do not alert the user
  2. Document the concern
  3. Report to your compliance team
  4. File SAR/STR as required by your jurisdiction

To Lumo

Report concerns to our compliance team:

Consequences of Violations

Violations of this policy may result in:

  • Transaction blocking or reversal
  • Account suspension
  • Termination of service
  • Reporting to authorities
  • Legal action

Updates

This policy may be updated periodically. Material changes will be communicated via email. Continued use of the Service constitutes acceptance of the updated policy.

Questions

For compliance-related questions, contact: