⚠️ Draft — placeholder text pending legal review. This is not legal advice and not the final agreement.

AML & KYC Policy

Last updated: — · Draft v0.1

Our commitment

Lumera and its partners operate under anti-money-laundering (AML) and counter-terrorist-financing rules. We apply a risk-based approach.

Identity verification (KYC)

Before using cards you complete identity verification, including document and liveness checks (via our KYC provider, e.g. Sumsub).

Sanctions & PEP screening

We screen customers against applicable sanctions lists and politically-exposed-person (PEP) databases, before onboarding and on an ongoing basis.

Ongoing monitoring

Transactions are monitored for suspicious patterns. We may request additional information or documents at any time.

Suspicious activity

We may pause or decline transactions, freeze cards or close accounts to comply with our obligations. We may be legally prohibited from explaining specific reasons.

Record keeping

KYC and transaction records are retained for the period required by law.

Your obligations

Provide accurate information, keep your details up to date, and do not use the service for unlawful purposes.