AML Policy

Lionere is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures and controls to prevent the use of our platform for money laundering or terrorist financing purposes.

We implement comprehensive KYC procedures to verify the identity of all customers. This includes:

• Valid government-issued photo identification (passport, national ID, driver's license)
• Proof of address documentation (utility bill, bank statement dated within 3 months)
• Source of funds verification for high-value transactions
• Enhanced due diligence for politically exposed persons (PEPs)

We employ sophisticated transaction monitoring systems to detect suspicious activities:

• Real-time monitoring of all transactions
• Automated alerts for unusual patterns or high-value transactions
• Regular review of customer activity profiles
• Cross-referencing with international sanctions lists

When suspicious activity is detected, we take immediate action:

• Suspicious Activity Reports (SARs) are filed with relevant authorities
• Account activity may be frozen pending investigation
• Full cooperation with law enforcement agencies
• Confidential handling of all reports

We conduct ongoing risk assessments to identify and mitigate potential money laundering risks:

• Customer risk profiling based on various factors
• Geographic risk assessment
• Product and service risk evaluation
• Regular policy reviews and updates

All employees receive comprehensive AML training:

• Initial training upon hiring
• Annual refresher courses
• Role-specific specialized training
• Updates on regulatory changes and emerging threats

We maintain comprehensive records in compliance with regulatory requirements:

• Customer identification documents retained for minimum 5 years
• Transaction records kept for the legally required period
• Secure storage with appropriate access controls
• Regular audits of record-keeping practices

We strictly comply with all applicable sanctions regimes:

• Real-time screening against OFAC, EU, UN sanctions lists
• Prohibition of services to sanctioned individuals/entities
• Geographic restrictions for sanctioned jurisdictions
• Regular updates to screening databases