AML/KYC Policy

Our commitment to preventing money laundering and ensuring regulatory compliance.

Last Updated: March 18, 2026

1. Introduction

LightningEX is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. This policy outlines our procedures for preventing, detecting, and reporting suspicious activities that may be related to money laundering, terrorist financing, or other illegal activities.

We comply with all applicable laws and regulations regarding AML and KYC, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and regulations issued by the Financial Crimes Enforcement Network (FinCEN).

2. Definitions

  • Money Laundering: The process of disguising the origins of money obtained through illegal means to make it appear legitimate
  • Terrorist Financing: The provision of funds or financial support to terrorist organizations or activities
  • KYC (Know Your Customer): The process of verifying the identity of our users
  • AML (Anti-Money Laundering): The comprehensive set of laws, regulations, and procedures designed to prevent money laundering
  • PEP (Politically Exposed Person): Individuals who hold or have held prominent public positions

3. Customer Identification Program

LightningEX implements a risk-based approach to customer identification. Depending on the nature and volume of transactions, we may require users to provide:

  • Full legal name
  • Date of birth
  • Residential address
  • Government-issued identification
  • Proof of address
  • Source of funds documentation

All identification documents are verified through reliable, independent sources to ensure authenticity.

4. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect suspicious activities, including:

  • Unusual transaction patterns or volumes
  • Transactions involving high-risk jurisdictions
  • Rapid movement of funds (layering)
  • Transactions inconsistent with user's stated purpose
  • Multiple transactions just below reporting thresholds

Any suspicious transactions are promptly investigated and reported to the appropriate authorities when necessary.

5. Sanctions Compliance

LightningEX strictly complies with all applicable sanctions programs, including those administered by:

  • The Office of Foreign Assets Control (OFAC)
  • The United Nations Security Council
  • The European Union
  • Other relevant regulatory bodies

We screen all users and transactions against international sanctions lists and will not process transactions involving sanctioned individuals, entities, or jurisdictions.

6. Record Keeping

We maintain comprehensive records of all transactions and customer identification information for a minimum of seven (7) years. These records include:

  • Transaction details (amounts, currencies, dates, addresses)
  • Customer identification documents
  • Correspondence with customers
  • Suspicious activity reports
  • Compliance training records

7. Suspicious Activity Reporting

Our compliance team is trained to identify and report suspicious activities. When suspicious activity is detected:

  • The activity is immediately escalated to the Compliance Officer
  • An investigation is conducted to determine if the activity is suspicious
  • If warranted, a Suspicious Activity Report (SAR) is filed with FinCEN
  • The customer is not notified of the investigation or filing

8. Employee Training

All LightningEX employees receive regular training on AML/KYC requirements, including:

  • Recognizing signs of money laundering and terrorist financing
  • Customer identification and verification procedures
  • Transaction monitoring and reporting obligations
  • Sanctions compliance
  • Record keeping requirements

9. Prohibited Activities

The following activities are strictly prohibited on the LightningEX platform:

  • Using the Platform for money laundering or terrorist financing
  • Providing false or misleading information during registration
  • Using the Platform if you are subject to any sanctions
  • Attempting to circumvent transaction limits or monitoring
  • Using the Platform for illegal gambling or other unlawful activities

10. Cooperation with Authorities

LightningEX cooperates fully with law enforcement and regulatory authorities in the investigation of financial crimes. We will provide information and assistance as required by applicable laws and regulations.

11. Contact Information

For questions regarding our AML/KYC Policy or to report suspicious activity, please contact our Support Department:

Email: support@lightningex.io
Address:
LightningEX Support Department
1425 Curtis Street Suite 41
Denver, CO 80202
United States