Last updated: March 2021
This is Luno’s approach to anti-money laundering (AML) and know-your-customer (KYC) processes
Money laundering is the process whereby the financial proceeds of a crime are disguised to give the impression of legitimate income. Often criminals target financial service providers through which they attempt to launder criminal proceeds without raising suspicion. In many cases, laundered funds are used to fund further crime or to finance terrorism. Sometimes both.
As a means to combat money laundering and to counter terrorist financing (CTF), most countries have implemented AML and CTF legislation which imposes obligations on financial service providers. Although it is not always clear in some of our countries, where we have a presence, whether these obligations fall on cryptocurrency providers, these laws, together with guidance from regulators, applicable task forces and industry best practice, form the cornerstone of Luno’s approach to AML and CTF. As such, Luno has implemented systems and controls that meet the standards applicable to regulated sectors such as banking. This decision reflects our desire to prevent money laundering and terrorist financing.
Key components of Luno's AML and CTF framework include the following:
- The appointment of a Money Laundering Reporting Officer (MLRO). This is an individual with a sufficient level of seniority and independence who is tasked with the responsibility of overseeing compliance with the relevant legislation, regulations, rules and industry guidance;
- The appointment of an independent risk committee which reports to our board of directors regularly on all risk and compliance matters;
- Establishing and maintaining a risk-based approach to the assessment and management of money laundering and terrorist financing risks;
- Establishing and maintaining a risk-based approach to Customer Due Diligence (CDD), including customer identification, verification and KYC procedures. To ensure we meet these standards, our customers are required to provide certain personal details and documents when opening a Luno Account. The nature and extent of what is required is guided by the customer’s deposit and withdrawal limits and, in some cases, the customer’s country of residence. In certain circumstances, Luno may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes and Politically Exposed Persons (PEPs);
- Establishing and maintaining risk-based systems and procedures for the monitoring of ongoing customer activity;
- Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- Maintaining appropriate KYC records for the minimum prescribed periods;
- Providing training on the framework and raising awareness among all relevant employees;
- Implementing a “travel-rule” framework, where this is required, to facilitate the exchange of customer information between virtual asset service providers when sending and receiving cryptocurrency. The nature and extent of what is required is dependent on the sender and/or receiver’s country of residence;
- Designing systems and controls to allow Luno to comply with all required sanction screening processes imposed by, for example, the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) and to take measures to prevent transacting with individuals, companies and countries appearing on these sanctions lists.