AML/CFT Policy

1. Policy Statement

Lookinex is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) compliance. We recognize that our platform, as a financial service involving cryptocurrency, carries inherent risks of being misused for financial crime.

This policy establishes the framework by which Lookinex detects, prevents, and reports money laundering, terrorism financing, and other financial crimes. All users, employees, and agents of Lookinex are required to comply with this policy and applicable laws and regulations.

2. Our Commitment

Lookinex commits to:

• Never knowingly facilitating or enabling money laundering, terrorism financing, or any other financial crime
• Implementing robust Know Your Customer (KYC) procedures to verify user identity
• Monitoring transactions for suspicious patterns and reporting to relevant authorities when required
• Screening all users against international sanctions lists
• Maintaining comprehensive records of all transactions and KYC documentation
• Training staff to recognize and respond to financial crime indicators
• Refusing or exiting relationships with users who present unacceptable AML/CFT risk

3. Know Your Customer (KYC) Requirements

Lookinex applies a tiered KYC framework based on transaction thresholds and risk assessment:

KYC submissions are reviewed within 1–3 business days. Users will be notified by email of approval or rejection with a reason. Lookinex may request additional documentation at any tier if risk indicators are present.

4. Prohibited Persons and Entities

Lookinex does not accept or maintain relationships with:

• Any individual or entity on the OFAC Specially Designated Nationals (SDN) list
• Any individual or entity subject to EU, UN, or UK financial sanctions
• Politically Exposed Persons (PEPs) without enhanced due diligence approval
• Shell companies or entities with no identifiable ultimate beneficial owner
• Anonymous accounts or accounts using false identity information
• Individuals residing in or nationals of comprehensively sanctioned jurisdictions (currently including Iran, North Korea, Cuba, Syria, and others as updated by relevant authorities)

5. Sanctions Screening

All users are screened against international sanctions lists at the time of registration and periodically thereafter, including:

• OFAC SDN and Consolidated Sanctions List (USA)
• EU Consolidated Financial Sanctions List
• UN Security Council Consolidated List
• UK Office of Financial Sanctions Implementation (OFSI) List

If a match is identified, the account is immediately frozen pending review. If confirmed, the account is closed, funds are frozen in accordance with applicable sanctions regulations, and the matter is reported to the relevant authority.

6. Transaction Monitoring

Lookinex employs automated transaction monitoring systems to detect unusual or suspicious activity. Patterns that may trigger additional review include:

• Large single deposits significantly exceeding a user's stated financial profile
• Rapid deposit and withdrawal patterns with no clear investment purpose
• Deposits from wallet addresses associated with darknet markets, ransomware, or other illicit sources
• Structuring transactions below reporting thresholds to avoid detection
• Transactions inconsistent with a user's KYC information or stated source of funds
• Sudden large increases in deposit volumes without a plausible explanation
• Deposits from or withdrawals to high-risk jurisdictions

7. Suspicious Activity Reporting

Where Lookinex reasonably suspects that a transaction or user account involves money laundering, terrorism financing, or other financial crime, we are obligated to file a Suspicious Activity Report (SAR) or equivalent report with the relevant Financial Intelligence Unit (FIU) or law enforcement authority.

Important: We are legally prohibited from informing (tipping off) the user that a SAR has been or may be filed. If your account is temporarily restricted or a transaction is delayed without explanation, this may be due to a compliance review in progress.

8. Blockchain Analytics

Lookinex uses blockchain analytics tools to assess the risk profile of cryptocurrency addresses used for deposits and withdrawals, identifying associations with known illicit addresses, mixer or tumbler usage, and source of funds risk scores. Deposits from wallets with unacceptably high risk scores may be rejected or held for manual review.

9. Source of Funds

All invested funds must originate from legitimate, verifiable sources including employment income, business income, sale of assets, inheritance, or investment returns from verifiable sources. Unacceptable sources include proceeds of criminal activity, funds derived from tax evasion, funds from sanctioned individuals or entities, and funds with unknown or unverifiable origins.

10. No Cash or Anonymous Payments

Lookinex does not accept cash, cash equivalents, money orders, prepaid anonymous cards, or any other form of anonymous payment. Deposits from privacy coins (Monero, Zcash shielded transactions) are not accepted. All deposits must be made from identifiable cryptocurrency addresses traceable to the depositing user.

11. Record Keeping

Lookinex maintains the following records for a minimum of 5 years following account closure:

• KYC documentation and identity verification records
• Account opening records and correspondence
• Transaction records (all deposits, withdrawals, profit distributions)
• Blockchain analytics reports and sanctions screening records
• SAR filings and supporting documentation
• Staff training records

12. Staff Training

All Lookinex employees and contractors with access to financial data or user accounts are required to complete AML/CFT training upon onboarding and annual refresher training thereafter. Training covers recognition of money laundering methods, red flags in cryptocurrency transactions, KYC procedures, sanctions compliance, and SAR filing obligations.

13. Risk-Based Approach

Lookinex applies a risk-based approach to AML/CFT compliance, allocating greater compliance resources and applying more stringent controls to higher-risk users, transactions, and geographies. Risk factors considered include jurisdiction of residence, transaction size and frequency, source of funds complexity, PEP status, and blockchain analytics risk scores.

14. Right to Refuse or Terminate

Lookinex reserves the right at any time, without liability, to refuse to open an account for any applicant, refuse any deposit or withdrawal transaction, freeze an account pending AML/CFT investigation, close any account presenting unacceptable AML/CFT risk, and report any suspicious activity to relevant authorities. Where an account is closed for AML/CFT reasons, funds may be held pending regulatory guidance.

15. Policy Review

This AML/CFT Policy is reviewed at least annually by the Lookinex compliance function and updated as needed to reflect changes in applicable law, regulatory guidance, and industry best practices.

16. Contact

For AML/CFT compliance queries: compliance@lookinex.com

To report suspected financial crime: compliance@lookinex.com

Lookinex takes financial crime seriously. If you have information about suspicious activity on the platform, please contact us immediately.