# 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:

- Telegram: [@lumo_support_bot](https://t.me/lumo_support_bot)


## 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:

- Telegram: [@lumo_support_bot](https://t.me/lumo_support_bot)