Prohibited business activities - Lumx

Every customer has to fully disclose their business activities to Lumx during onboarding and on an ongoing basis. We use that disclosure to run the right risk assessment, apply the right controls, and stay compliant with AML/CFT, sanctions, and regulatory requirements. Not disclosing relevant activity can lead to onboarding rejection, account suspension, or termination.

High-risk business activities

Allowed with disclosure, risk assessment, and Enhanced Due Diligence. Being in one of the categories below doesn’t disqualify you — it triggers EDD and ongoing monitoring. You have to disclose these activities up front. This list isn’t exhaustive:

Money services, payment processing, or funds transmission (MSBs, PSPs, P2P platforms, prepaid or gift cards, ATM operators)
Licensed lending, foreign exchange, and securities brokerage
Virtual asset service providers (VASPs): crypto exchanges, OTC desks, wallet providers, custody or escrow, stablecoin issuers
Decentralized finance (DeFi), DAOs, foundations, gaming, metaverse, or other virtual asset ecosystems
Issuing, holding, safeguarding, or managing client funds, digital assets, stablecoins, or wallets
Trading, brokering, or dealing in high-value or trade-exposed goods — precious metals and stones, jewelry, oil and gas, mining, agriculture, construction, and real estate
Cash-intensive businesses — convenience stores, liquor retail, restaurants operating on cash, car washes
Licensed gambling, betting, or gaming operators
Crowdfunding platforms
Licensed investment advisors and asset managers
Businesses with complex or multi-layered ownership structures
Customers where a principal owner or controlling person is a politically exposed person (PEP)

High-risk customers may be asked for additional documents via Request for Information. Plan for verification windows beyond the standard SLA.

Prohibited business activities

Not supported under any circumstances. Lumx doesn’t serve businesses engaged in the following activities, directly or indirectly, regardless of jurisdiction or licensing claims.

Category	Description
Adult content and sexually oriented services	Businesses offering or facilitating sexually explicit, obscene, or adult-oriented content or services.
Drugs, controlled substances, and unlicensed pharmaceuticals	Sale, distribution, or facilitation of illegal or controlled substances, including cannabis and unlicensed pharmaceuticals.
Tobacco and tobacco-related products	Manufacture, distribution, or sale of tobacco products and related services.
Weapons, ammunition, and explosives	Trading or dealing in weapons, firearms, ammunition, or weapon-related products.
Unlicensed gambling, betting, and games of chance	Any business involving unlicensed or prohibited games of chance, betting, or casinos. Licensed operators fall under high-risk.
Fraudulent and predatory financial models	Ponzi schemes, pyramid schemes, deceptive practices, and abusive or predatory lending.
Unlicensed money services	Money transmitters, payment processors, virtual asset providers, and remittance operators without the required licenses in their jurisdiction.
Shell banks and unsupervised banking structures	Shell banks, offshore banks without physical presence, correspondent accounts for shell banks, payable-through accounts, and concentration accounts. See Nested Payments.
Unlicensed investment products and funds	Non-deposit investment products, trust and asset-management services, and trade finance operations without the required licenses.
Client trust and pass-through accounts	IOLTA-style lawyer trust accounts, escrow accounts on behalf of unidentified beneficiaries, and any structure where Lumx-held funds belong to a non-onboarded party. See Nested Payments.
Hate, violence, terrorism, and discriminatory activity	Activities promoting or enabling harm, hate, exploitation, or terrorism, including known terrorist organizations.
Sanctioned and illicit entities	Entities or individuals on OFAC, EU, UN, UK, or other sanctions lists, or operating from jurisdictions under comprehensive embargoes. See Supported countries.
Identity fraud, anonymity misuse, and shell structures	Anonymous or fictitious accounts, bearer-share companies, or entities designed to obscure beneficial ownership.
Intellectual property infringement and counterfeit goods	Entities selling, distributing, or enabling IP-infringing or counterfeit products.
Data misuse and consumer privacy violations	Businesses that compromise customer data or privacy.
Governmental, diplomatic, and political entities	Government bodies, embassies, consulates, supranational organizations, and diplomatic entities.
Charities and NGOs	Non-governmental organizations, charitable foundations, and non-profit entities.

Consequences of violation

If prohibited activity is found on a Lumx account:

The account is reviewed and may be suspended or terminated.
Funds may be frozen pending investigation.
Partners and authorities may be notified, in line with legal and contractual obligations.

Reporting violations

If you spot prohibited activity on the platform, email compliance@lumx.io.

Supported countries

Jurisdiction tiers and where Enhanced Due Diligence applies.

Identity Verification

KYC and KYB requirements for individuals and businesses.

Nested Payments

Visibility rules and why pass-through structures are restricted.

Request for Information

Resolve RFIs raised during enhanced due diligence.