AML Policy

Anti-Money Laundering and Know Your Customer Policy of LunaGate LTD (operator of www.29black.com)

1. Introduction
2. www.29black.com is operated by LunaGate LTD, a company incorporated under the laws of the Autonomous Island of Anjouan, Union of Comoros, with registered office at Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros.
3. LunaGate LTD is committed to maintaining the highest standards of integrity, transparency, and security across all operations. To prevent money laundering and the financing of terrorism, 29Black implements a robust Anti-Money Laundering (AML) and Know Your Customer (KYC) framework in accordance with international regulations and best practices.
4. Objective of the AML Policy
5. The purpose of this policy is to:
6. Protect www.29black.com and its customers from fraudulent and illegal financial activities.
7. Verify the identity of customers and ensure that payment methods used belong to the registered account holder.
8. Establish a transparent and traceable system of transactions to detect and prevent money laundering or other illicit financial behavior.
9. 29Black applies a three-step verification process to confirm customer identity, verify ownership of funds, and ensure compliance with applicable AML/KYC laws.
10. Regulatory Compliance
11. The AML framework of www.29black.com is designed to comply with:
12. EU Directive 2015/849 on the prevention of the use of the financial system for money laundering or terrorist financing.
13. EU Regulation 2015/847 on information accompanying transfers of funds.
14. Various EU and international sanctions and restrictive measures.
15. Best practices derived from the Financial Action Task Force (FATF) recommendations.
16. Definition of Money Laundering
17. Money laundering refers to any activity intended to disguise the origin of funds obtained through criminal means. It includes, but is not limited to:
18. Converting or transferring property, knowing it is derived from criminal activity, to conceal its origin or assist others in evading legal consequences.
19. Concealing or disguising the true nature, source, location, movement, or ownership of property derived from criminal activity.
20. Acquiring, possessing, or using property while knowing it originates from criminal activity.
21. Participating in, assisting, or facilitating any of the above activities.
22. Money laundering is recognized as such even when the related offenses occur outside the jurisdiction of Anjouan or the country of residence of the individual involved.
23. AML Organization and Responsibilities
24. LunaGate LTD has established internal procedures to ensure effective implementation of this AML/KYC policy.
25. A designated Anti-Money Laundering Compliance Officer (AMLCO) oversees the daily application of AML controls and reports directly to management.
26. All staff handling customer interactions, payments, or verifications receive AML awareness and training.
27. Three-Step Verification Process
28. Step 1 - Basic Verification
29. Required for all customers before making a withdrawal.
30. Customers must complete a registration form providing accurate personal details including:
31. Full name
32. Date of birth
33. Country of residence
34. Gender
35. Full residential address
36. Step 2 - ID Verification
37. Customers must provide:
38. A valid government-issued photo ID (Passport, ID card, or Driver’s license)
39. Proof of address (e.g., recent utility bill or government registration document in the last 3 months) if electronic verification fails.
40. Transactions are held until verification is successfully completed.
41. Step 3 - Enhanced Verification
42. Required for customers who:
43. Deposit or withdraw more than €5,000.
44. Enhanced verification may include:
45. Source of funds or source of wealth documentation.
46. Additional ID verification or video call verification.
47. Ongoing monitoring of transactions for unusual or suspicious activity.