# 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)