Anti-Money Laundering & Know Your Customer Policy

1. Purpose and scope

This policy applies to every merchant account and every transaction processed through LotiFinance.

2. Customer due diligence

Before an account can process live payments, we require:

• A full name, a government-issued ID, and a live selfie for identity verification.
• For registered organizations: the company name, registration number and business address, plus any supporting documents we request.

Submissions are reviewed by our team before an account is approved for live payments. An account can remain pending, be approved, or be rejected.

3. Ongoing monitoring

We monitor accounts for activity that is unusual or inconsistent with the information provided at verification. We may request additional information at any time, and our team can suspend an account whenever there is a concern about the legitimacy of a user or a transaction.

4. Prohibited customers and transactions

We do not knowingly provide the Service to, or process transactions for:

• Individuals or entities subject to applicable sanctions.
• Shell entities with no identifiable legitimate business purpose.
• Transactions for illegal goods or services.
• Activity structured to avoid verification or reporting requirements.

5. Reporting

Where we identify activity that appears unlawful or inconsistent with a merchant's stated business, we may decline or reverse transactions, suspend the account, and — where required by law — report the activity to the relevant authorities in [Jurisdiction].

6. Record keeping

We retain verification records and transaction history for as long as an account is active and as required by applicable law.

7. Compliance oversight

This policy is maintained and reviewed by [Compliance Officer / Team Name].

8. Cooperation with authorities

We cooperate with regulators and law enforcement in accordance with applicable law.

9. Policy review

We review this policy periodically and update it to reflect our evolving controls and applicable regulation.