Anti-Money Laundering Policy

1. Purpose

The purpose of this Policy is to:

1. Establish procedures to detect, prevent, and report suspicious activity.
2. Comply with legal obligations under applicable AML and counter-terrorism financing laws.
3. Protect LUNO, its Users, and its ecosystem from reputational, financial, and regulatory risk.

2. Scope

This Policy applies to:

• All Users engaging in NFT purchases, sales, or transfers.
• Employees, contractors, and third-party service providers involved in transaction processing, customer verification, or compliance monitoring.
• All jurisdictions in which LUNO operates or offers Services.

3. Know Your Customer (KYC)

To comply with AML obligations, LUNO may require Users to provide KYC verification, which may include:

• Full legal name
• Date of birth
• Government-issued identification (passport, driver's license, national ID)
• Proof of residential address
• Any other information necessary to verify identity or comply with legal requirements

KYC Verification Requirements:

• Transactions above certain thresholds may require mandatory KYC approval before processing.
• Users who fail to complete KYC verification may be restricted from using the Services or transferring NFTs.

4. Transaction Monitoring

LUNO implements procedures to monitor transactions and detect unusual or suspicious activity, including but not limited to:

• Large or irregular NFT purchases, transfers, or trades
• Rapid flipping or layering of NFTs across wallets
• Transactions involving wallets or jurisdictions subject to sanctions or blacklists

Suspicious activity will be investigated and reported to relevant authorities in accordance with applicable law.

5. Sanctions Compliance

LUNO strictly prohibits transactions involving:

• Individuals, entities, or wallets listed on sanctions lists maintained by the Office of Foreign Assets Control (OFAC), the European Union, the United Kingdom, or the United Nations.
• Parties subject to any other legal restrictions or prohibitions.

All Users must ensure they do not engage in transactions with prohibited persons or jurisdictions.

6. Record Keeping

LUNO maintains records of:

• KYC verification and identity documents
• Transaction histories, including wallet addresses and NFT activity
• Suspicious Activity Reports (SARs) submitted to authorities

Records are retained in compliance with local laws and international best practices for a period required by regulation.

7. Reporting Obligations

LUNO employees and compliance personnel are required to:

1. Report any suspicious transactions or behavior promptly to the AML Compliance Officer.
2. Submit Suspicious Activity Reports (SARs) to relevant regulatory or law enforcement authorities where required.

All reports and investigations are handled with strict confidentiality.

8. Employee and Partner Responsibilities

• Employees and third-party service providers must undergo AML and compliance training.
• All employees must adhere to this Policy and report suspicious activity without delay.
• Failure to comply with this Policy may result in disciplinary action, termination, or legal consequences.

9. Risk Assessment

LUNO conducts periodic risk assessments to identify and mitigate vulnerabilities related to:

• Customer verification processes
• NFT transactions and marketplace activity
• Integration with third-party services or blockchains
• Regulatory changes or emerging financial crime trends

10. Review and Updates

This Policy is reviewed regularly to ensure compliance with legal requirements, industry standards, and emerging risks. LUNO reserves the right to update this Policy at any time. The most recent version will be available on the Website and becomes effective immediately upon posting.