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AML / KYC Policy

Anti-Money Laundering / Counter-Terrorist Financing / Know Your Customer Policy

Lucidum Enterprises Ltd. S.A. de C.V. ("Lucidum", "we", "us", or "the Company") is fully committed to the highest international standards of Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and prevention of financing the proliferation of weapons of mass destruction (PFWMD).

Compliance Framework

The Company maintains a formal internal AML/CTF Compliance Manual and its governance framework was approved by shareholders, including:

  • • creation of a Compliance Officer role
  • • establishment of a Compliance Committee
  • • approval of the AML/CTF Compliance Manual
  • • annual audit & training plan approval

Regulatory Compliance

Lucidum complies with:

  • • Ley Contra el Lavado de Dinero y Activos (El Salvador AML Law)
  • • Digital Asset Issuance Act and Bitcoin Law
  • • Financial Investigation Unit (FIU) regulations
  • • FATF Recommendations on AML/CTF

We cooperate fully with regulatory authorities and law enforcement.

Customer Due Diligence (CDD)

Before opening any account or processing any transaction, Lucidum must:

  1. Identify & verify customer identity
  2. Screen customer against sanctions, PEP status, adverse media
  3. Assess customer risk rating (Low, Medium, High)
  4. Apply Enhanced Due Diligence (EDD) when required

The Company performs CDD/KYC before onboarding or when transactions exceed regulatory threshold.

Prohibited activities

The following activities are strictly prohibited:

  • • Anonymous accounts / fake identities
  • • Shell banks relationships
  • • Transactions with sanctioned persons / jurisdictions

Monitoring & Reporting

We continuously monitor transactions for suspicious activities and report to relevant authorities as required by law. All transactions are subject to our compliance review procedures.

Record Keeping

We maintain detailed records of all customer information, transactions, and compliance activities for the period required by applicable laws and regulations.

Policy Updates

This AML/KYC policy is subject to regular review and updates to ensure compliance with evolving regulatory requirements and industry best practices.

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