AML & KYC Policy

Lucrosus Capital Anti-Money Laundering and Know You Customer

Your Customer Policy (hereinafter – “AML and KYC Policy”) is designated to prevent and mitigate possible risks of Lucrosus Capital being involved in any kind of illegal activity. Both international and local regulations require Lucrosus Capital to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

This AML and KYC Policy applies to both natural and legal persons. Legal entities joining the Lucrosus Capital Public Sale, which is defined as making a Lucrosus Capital purchase in a specific method stated in clause 4 of this AML and KYC Policy, will receive purchased tokens to their wallet’s address after required AML and KYC procedures that include providing specific documents.

AML and KYC Policy covers the following matters:

1. Verification procedures.

1.1. Basis

1.2. Identity verification

1.3. Anti-money laundering procedure

1.4. Authenticity verification

1.5. Right to report

1.6. Continuous basis of information verification

1.7. Transaction proceed refusal

1.8. Payment cancellation

2. Compliance Officer.

2.1. Definition

2.2. Duties

2.3. Law enforcement

3. Monitoring Transactions.

3.1. Data analysis

3.2. Suspicious transactions reporting

4. Payment methods.

4.1. Payments

4.2. PayPal usage control

4.3. Coinbase transfer control

4.4. NOWPayments transfer control

4.5. Address analysis

4.6. Liability

4.7. Due diligence

5. Risk Assessment.

6. AML and KYC Policy.

6.1. Acceptance

6.2. Privacy Policy

1. Verification procedures

1.1. Basis

One of the international standards for the prevention of illegal activities is Know Your Customer (“KYC”). According to the KYC, Lucrosus Capital establishes its own verification procedures within the framework of anti-money laundering standards and Know Your Customer.

1.2. Identity verification

Lucrosus Capital’s identity verification procedure requires the User to provide reliable, independent sources of documents, data or information (e.g. ID card, international passport, bank statement, utility bills;) every time the User is requested to provide certain information. For AML and KYC Policy purposes, Lucrosus Capital hereby reserves the right to collect User information.

1.3. Anti-money laundering procedure

Lucrosus Capital’s anti-money laundering procedure requires the User to provide information about the source of the funds the User uses to purchase Lucrosus Capital tokens every time the User is requested to provide certain information. Lucrosus Capital is not responsible for any errors or omissions in the information provided by the User.

1.4. Authenticity verification

Lucrosus Capital shall take steps to verify the authenticity of documents and information provided by Users, use all legal methods to double-check identification information and hereby reserves the right to investigate the actions of certain Users that have been found risky or suspicious.

1.5. Right to report

We may therefore report our suspicions regarding any activity of the users to local regulators, enforcement bodies and other compliance bodies. Those kinds of actions aim to ensure that the capital being used on our platform has a legitimate origin and create a safeguard in case of individuals or groups wanting to allocate their money from illegal activities on our platform.

1.6. Continuous basis of information verification

Lucrosus Capital hereby reserves the right to continuously verify the User’s identity, significantly when the verification information has been changed or the User’s activity has been deemed suspicious, even if they have already undergone identity verification. User verification information shall be collected, stored, transferred and protected strictly by Lucrosus Capital’s Data Protection Policy and the relevant rules. Following the user’s identity verification, Lucrosus Capital disclaims potential legal liability in situations where its Services are used for illegal activities.

1.7. Transaction proceed refusal

Lucrosus Capital may refuse to move the transaction of transferring the purchased tokens to the User if the User refuses to provide any demanded information.

Lucrosus Capital may refuse to issue tokens to the User if:

a. The User does not provide any demanded information to Lucrosus Capital and enables to complete any diligence procedures on the User;

b. The User has been previously identified as engaged in the suspicious activity;

c. The User is the citizen of a country considered to be exposed to a high risk of money laundering or financing terrorism;

d. The User is listed on a sanctions list in any of the jurisdictions to which Lucrosus Capital may transfer purchased tokens, or Lucrosus Capital otherwise identifies the User as exposed to a high risk of money laundering or financing terrorism.

1.8. Payment cancellation

The User cannot cancel a request to purchase the tokens. Lucrosus Capital may cancel the User’s purchase of the tokens if it is impossible to verify the User’s identity or conduct any other procedures that Lucrosus Capital is required to complete. Lucrosus Capital may not refund the User any amount until the User has provided any demanded information required by law.

2. Compliance Officer

2.1. Definition

The Compliance Officer is the person duly authorised by Lucrosus Capital, whose duty is to ensure the effective implementation and enforcement of the AML and KYC Policy.

2.2. Duties

It is the Compliance Officer’s responsibility to supervise all aspects of Lucrosus Capital’s anti-money laundering and counter-terrorist financing, including but not limited to:

a. Collecting User’s identification information;

b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;

c. Monitoring transactions and investigating any significant deviations from regular activity;

d. Implementing a record management system for appropriate storage and retrieval of documents, files, forms and logs;

e. Updating risk assessment regularly;

f. Providing law enforcement with information as required under the applicable laws and regulations.

2.3. Law enforcement

The Compliance Officer is entitled to interact with law enforcement, which is involved in preventing money laundering, terrorist financing and other illegal activity.

2.4. Contact with the clients and authorities

The Compliance Officer is obliged to communicate effectively with the clients and authorities having any complaints or questions that are being addressed to him regarding the Lucrosus Capital AML and KYC Policy and its implementation to ensure the transparency and credibility of the platform. The address to contact the Compliance Officer is [email protected]. Any kind of correspondence sent to the Compliance Officer will be addressed by him within the time frame of 5 working days.

3. Monitoring transactions

3.1. Data analysis

User verification is carried out not only by checking their identity but also by analysing transaction models. Lucrosus Capital, therefore, relies on data analysis as a tool for assessing risk and identifying suspicions. Lucrosus Capital carries out many regulatory compliance tasks, including data collection, filtering and record keeping.

3.2. Suspicious transactions reporting

With regard to the AML and KYC Policy, Lucrosus Capital will monitor all transactions, and it reserves the right to ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer and request the User to provide any additional information and documents in case of suspicious transactions. Compliance Officer will monitor the User’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

4. Payment methods

4.1. Payments

The User may purchase Lucrosus Capital’s token by transferring any token or cryptocurrency by Coinbase Commerce, NOWPayments or by card using Advcash. To carry out a transaction in a chosen way, the User must follow the relevant instructions on the Lucrosus Capital site.

4.2. Advcash and other card payment provider usage control

Lucrosus Capital may refuse to complete or block, cancel or reverse a transaction of the Lucrosus Capital’s token purchase made with Advcash (Adcash (South America) Unit 104, #16 A Street. King’s Park, Belize City, Belize) or any other card provider usage if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action. Lucrosus Capital is under no obligation to disclose the details of its credit card risk management and security procedures to the User.

4.3. Coinbase Commerce transfer control

Lucrosus Capital may refuse to complete or block, cancel or reverse a transaction of the Lucrosus Capital’s Token purchase made with Coinbase (Coinbase, Inc. 100 Pine Street, Suite 1250, San Francisco, CA 94111) usage if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action.

4.4. NOWPayments transfer control

Lucrosus Capital may refuse to complete or block, cancel or reverse a transaction of the Lucrosus Capital’s Token purchase made with NOWPayments (NOWPayments Ltd. House of Francis, Room 303, lle Du Port, Mahé, Seychelles) usage if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action.

4.5. Address analysis

Lucrosus Capital may analyze the token or cryptocurrency addresses against common blacklists and known security discrepancies, to ensure that the funds do not come from illicit sources, and there are no signs of money laundering (location, layers, integration), either manually or using a third-party service.

4.6. Liability

Lucrosus Capital has no control over, or liability for, the delivery, quality, safety, and legality or any other aspect of any goods or services received or purchased from Coinbase or card payment provider.

5. Risk assessment

Lucrosus Capital, in accordance with international requirements, takes a risk-based approach to combating money laundering and the financing of terrorism. Lucrosus Capital can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the identified risks by applying a risk-based approach. This makes it possible for resources to be allocated most efficiently. The principle is to allocate resources corresponding to priorities to give the highest risks the closest attention.

6. AML and KYC Policy

6.1. Acceptance

By joining the Lucrosus Capital Public Sale, which is defined as making a Lucrosus Capital’s token purchase in a specific method stated in clause 4 of this AML and KYC Policy, the User accepts the terms of this AML and KYC Policy and hereby agrees to have read, understood and accepted the Terms of Use and Data Protection Policy available at: https://docs.lucrosus.capital/. In addition, when using particular services, the User may be subject to additional agreements applicable to such services. The User must stop using the services and the website if they disagree with the AML and KYC Policy and the Terms of Use and Data Protection Policy.

6.2. Privacy policy

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Lucrosus Capital’s Privacy Policy and related regulations.

DISCLAIMER

This Public Sale is open internationally. Restrictions due to compliance regulations for different jurisdictions apply.

Restrictions due to compliance regulations for different jurisdictions apply. Residents from Afghanistan, Angola, Azerbaijan, Bahamas, Bosnia and Herzegovina, Botswana, Burundi, Cambodia, Cameroon, Canada, Chad, China, Congo, Congo (Democratic Republic), Cuba, Eritrea, Ethiopia, Ghana, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Japan, Lao People’s Democratic Republic, Libya, Madagascar, Mozambique, Nicaragua, North Korea, Pakistan, Seychelles, Somalia, South Korea, South Sudan, Sri Lanka, Sudan, Syrian Arab Republic, Tajikistan, Trinidad and Tobago, Tunisia, Turkmenistan, Uganda, Ukraine, United-States, Uzbekistan, Vanuatu, Venezuela, Virgin Islands (British), Virgin Islands (U.S), Yemen, and Zimbabwe are not permitted to join this contest. Lucrosus Capital, nor any of its partners, are not responsible for any legal repercussions incurred due to the non-compliance of participants. The above tax law applies to users who must not participate in the Lucrosus Capital Public Sale.

Please consult the respective laws governing your region for the most accurate information.