Lupofi Anti-Money Laundering (AML) Policy

1. Introduction

Lupofi, a product of Lucrestack, is committed to maintaining the highest standards of integrity and compliance with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and regulations across the jurisdictions in which it operates. This policy aims to prevent the misuse of Lupofi’s platform for money laundering, terrorism financing, fraud, or other illicit financial activities.

2. Scope

This policy applies to all Lupofi employees, contractors, agents, partners, merchants, and users engaging in financial transactions through the platform. It also extends to third-party service providers involved in Lupofi’s financial services.

3. Regulatory Compliance

Lupofi adheres to the AML and CTF guidelines set forth by international regulatory bodies, including but not limited to:

• Financial Action Task Force (FATF) recommendations
• European Union (EU) AML Directives
• Bank Secrecy Act (BSA) in the U.S.
• United Nations Office on Drugs and Crime (UNODC) AML guidelines
• Local AML regulations in jurisdictions where Lupofi operates

4. Customer Due Diligence (CDD) & Know Your Customer (KYC)

To ensure compliance, Lupofi implements strict Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures, including:

4.1 Customer Identification & Verification (CIV)

All customers must provide valid identification documents before they can access Lupofi’s services. Required documents include:

• Government-issued ID (e.g., passport, national ID, or driver’s license)
• Proof of address (utility bill, bank statement, or similar)
• Phone number and email verification

4.2 Enhanced Due Diligence (EDD)

For high-risk customers (e.g., politically exposed persons (PEPs), customers from high-risk jurisdictions, or those with large transactions), additional verification steps may be required, including:

• Source of funds verification
• Additional documentation requests
• Close transaction monitoring

4.3 Ongoing Monitoring

Lupofi will continuously monitor customer transactions to detect suspicious activities, including:

• Unusual transaction volumes or patterns
• Transactions involving high-risk jurisdictions
• Rapid movement of funds without clear business purposes

5. Transaction Monitoring & Reporting

Lupofi deploys automated and manual transaction monitoring tools to flag suspicious activities. If any transactions exhibit red flags for money laundering or terrorist financing, Lupofi will:

• Conduct internal investigations
• File a Suspicious Activity Report (SAR) with relevant authorities
• Report transactions exceeding regulatory thresholds to Financial Intelligence Units (FIUs)

6. Record-Keeping & Compliance Reviews

Lupofi maintains all transaction records, customer identification details, and due diligence information for a minimum of 5 to 10 years, in compliance with global regulatory standards.

Regular internal AML audits will be conducted to assess the effectiveness of the company’s AML measures and ensure continuous compliance.

7. Training & Awareness

Lupofi conducts periodic AML training for employees, partners, and relevant stakeholders. Training covers:

• AML/CTF regulatory updates
• Identifying suspicious transactions
• Reporting obligations under AML laws

8. Cooperation with Regulatory Authorities

Lupofi fully cooperates with law enforcement agencies, financial regulators, and international bodies in their efforts to combat money laundering and terrorism financing.

9. Non-Compliance & Penalties

Any violation of this AML policy by an employee, partner, or customer will result in appropriate disciplinary action, which may include:

• Account suspension or termination
• Reporting to authorities
• Legal action in compliance with regulatory requirements

10. Policy Updates & Review

This AML Policy is subject to regular review and updates to ensure compliance with evolving global AML standards and regulations.