BSA/AML Programme

Bank Secrecy Act and Anti-Money Laundering Compliance Program

The Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) has been developed in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the United States. This includes, but is not limited to:

• Establishing robust internal policies, procedures and controls that combat any attempted use of the Lunu Pay Services for illegal or illicit purposes and that are designed to ensure Retailers and Customers basic protections under consumer protection laws;
• Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”);
• Filing Suspicious Activity Reports (“SARs”);
• Filing Currency Transaction Reports (“CTRs”);
• Maintaining comprehensive records of orders and other transfers and following record retention requirements;
• Employing a Chief Compliance Officer (“CCO”) to act as Bank Secrecy Act Officer and be responsible for the implementation and oversight of the BSA/AML Program;
• Executing Know Your Customer (“KYC”) procedures on all customers;
• Performing regular, independent audits of the BSA/AML Program; and
• Implementing a formal and ongoing compliance training program for employees.
• Policies and Procedures

The BSA/AML Program has been reviewed and approved by Lunu Pay’s Managers. The BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies. Lunu Pay has a FMSB registration from FinCen and the BSA/AML Program is subject to FinCen’s review and approval.

Internal Controls

Lunu Pay has developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page including, but not limited to, the Customer Identification Program (“CIP”), the filing of SARs and CTRs, as well as other reporting requirements and audits.

Training

Lunu Pay’s employees and officers receive ongoing broad-based BSA/AML training, as well as position-specific training. They must repeat this training at least once every twelve (12) months, and all new employees receive training, to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. All documentation related to compliance training including materials and attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.

Compliance Officer

Lunu Pay’s CCO is responsible for developing and enforcing the policies and procedures of the BSA/AML Program. Lunu Pay’s CCO is required to report any violations of our BSA/AML Program directly to the CEO and Managers. In addition, the CCO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least annually.

Customer Identification

The Customer Identity Program (“CIP”) is an important part of the BSA/AML Program, and helps Lunu Pay detect suspicious activity in a timely manner and prevent fraud.

In order to use the Lunu Pay Services, your identity must be verified, authenticated, and checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in your inability to use Lunu Pay Services.

If you successfully meet and complete our CIP requirements, we will complete your account onboarding.

We request the following documentation:

1. Copy of an ID or passport of every director and shareholder/UBO (who owns more than 20% of shares) and their proof of addresses;
2. Proof of the company address. We accept the following address verification documents, issued within 90 days:
   • bank statements — with transactions history — we accept digital bank statements too, just send us the original .pdf file (do note that sensitive information such as transactions details can be covered, transactions details);
   • utility bills - electricity, water, waste management, fixed internet or phone bills (no mobile phone bills and insurance letters), etc.
   • government issued letters — such as letters from government agencies, tax bills, etc.
3. Certificate of the Registration of Incorporation/ registry extract;
4. Memorandum of articles of Association / Constitution / By-Laws;
5. Confirmation of an active status of the company ( if it’s not indicated in Registration Extract);
6. Confirmation of the director ( if it’s not indicated in Registration Extract);
7. Ownership structure: list of all Shareholders with the specified number of shares.

Over the course of your customer experience on the platform, Lunu Pay’s team may reach out to you for additional information in order to ensure the safety and integrity of our customer base and our trading platform, and as required for ongoing compliance with our regulatory obligations. Please be aware that your failure to comply with these requests may result in restrictions on your account.

Suspicious Activity / Currency Transaction Reports Process

Lunu Pay files SARs if it knows, suspects or has reason to suspect suspicious activities have occurred while using the Lunu Pay Services. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. Lunu Pay leverages its compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. The CCO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.

In addition, all currency transactions over a determined USD value are reported to FinCEN via a CTR filing.

The CCO maintains records and supporting documentation of all SARs and CTRs that have been filed.

Reporting Requirements

All records are retained for eight (8) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.

BSA/AML Program Audit

Internal. The CCO is responsible for overseeing our BSA/AML Program and presenting findings to our CEO and Managers.

Independent. The CCO oversees the performance of an independent test of the BSA/AML Program at least annually. Results are shared with the Managers.