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Every jurisdiction falls into one of three tiers. The tier determines whether you can onboard a customer based there and how much compliance review they go through. Tiers reflect Lumx’s internal risk appetite, partner bank requirements, and external references (FATF guidance, UN, U.S. OFAC, EU, and UK sanctions lists), and are reassessed as those inputs change.

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Tiers

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Supported

Standard compliance procedures apply.
*Crimea, Donetsk, Luhansk, and any areas not under Ukrainian government control are restricted regardless of the country-level classification.

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High-Risk (EDD Required)

Onboarding is allowed, but every customer goes through Enhanced Due Diligence. Expect additional documents, beneficial-owner analysis, and longer verification windows.
EDD customers may be asked for additional documents via Request for Information. Plan for verification windows beyond the standard SLA.

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Restricted

No transactions, partnerships, or business relationships allowed. Onboarding a customer with any restricted nexus (residence, incorporation, principal place of business, or beneficial ownership) will be rejected.
Hidden exposure detected after onboarding can result in account suspension, freezing, or termination.

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Updates and exceptions

  • Classifications get reassessed as sanctions regimes, FATF guidance, and partner bank policies change.
  • Lumx may approve or refuse onboarding outside the standard tier in limited cases, based on a customer’s specific activity or counterparty exposure.
  • A country being Supported means Lumx will onboard the customer. It doesn’t guarantee a specific local payment rail. See Coverage for rails and currencies by country.
For grey-area cases or pre-approval requests, email compliance@lumx.io.

Coverage

Payment rails, currencies, and stablecoin pairs by country.

Identity Verification

KYC and KYB requirements per customer type.

Transaction Limits

Default thresholds and how EDD affects limits.

Request for Information

Resolve RFIs raised during enhanced due diligence.