AML and KYC policy

This page explains how Luminvestry verifies who its clients are and what it does to prevent its services being used for money laundering or the financing of crime. The policy is written to be read, not just published: each section answers one question in plain terms.

1. Introduction

Know Your Customer (KYC) procedures establish who you are; Anti-Money Laundering (AML) measures, known in some jurisdictions as PLD, prevent criminal proceeds passing through financial services; and Counter-Terrorist Financing (CTF) controls stop funds reaching proscribed organisations. Together they are the legal and practical foundation on which any legitimate financial platform operates, and their purpose is protective: for you, for other clients, and for the integrity of the system itself.

Verification happens once at onboarding and then continues quietly through the life of the account. Most users complete the initial step in a single sitting and never think about it again.

2. What KYC is

KYC is the identification of a client and confirmation that the data provided about them is genuine. In practice this means collecting your name, date of birth and address, checking the details against authoritative documents, and confirming that the person presenting those documents is you rather than someone using your identity.

Identification is not a one-off event. Records are kept current, and if your circumstances change, for example a new surname or a different residential address, updated details are requested the next time you use the platform.

3. What AML and PLD are

Anti-money laundering framework, referred to as PLD in some European legislation, is the set of controls designed to detect and prevent the integration of criminal money into lawful finance. AML work at Luminvestry has three components: a risk assessment of every client relationship, ongoing monitoring of account activity against what is expected, and the reporting of suspicious activity to the relevant authorities through the required channels.

These controls are not an accusation against anyone. They exist because the appearance of legitimacy is precisely what criminal money seeks, and the only defence is quiet, systematic checking.

4. Why identity verification is required

Verification serves four purposes. It prevents fraud by ensuring an account is opened by its true owner rather than an impostor. It protects existing clients, because a platform full of verified users is a hostile environment for stolen identities. It fulfils the legal obligations that apply to financial activity in the United Kingdom. And it reduces financial risk for everyone by keeping criminal funds, and the legal consequences that follow them, away from the platform.

Without completed verification an account cannot deposit, trade or withdraw. This is deliberate: the checks protect the moment money moves.

5. Documents we ask for

Identity is confirmed with a government-issued photographic document: a passport, driving licence or national identity card. Address is confirmed with a document less than three months old, such as a bank statement, utility bill or council tax letter, in your name at your current address. Where a document raises questions, or where regulation requires it, a short selfie or liveness check is used to confirm that the person submitting the documents is their live holder.

We do not ask for documents we cannot use, and we never ask for passwords, one-time codes or full card numbers. Anything requested appears in the platform's own verification screen, not in an email link.

6. The verification process, step by step

  1. Registration. You create the account with your name, email and phone number.
  2. Provision of data and documents. You upload your identity document and proof of address through the verification screen.
  3. Automatic checking. The system validates document authenticity, data consistency and, where applicable, the liveness result.
  4. Manual review where needed. If anything is ambiguous, a compliance officer reviews the file and may request a clearer scan or a supplementary document.
  5. Outcome. You are informed by email either that verification is complete or precisely what is still required.

7. Enhanced due diligence

Some situations call for a deeper look, a process known as enhanced due diligence. It applies where the client's profile, the source of funds, the geographic pattern of activity or the transaction sizes are unusual relative to what is expected. In such cases we may ask for evidence of the origin of funds, additional identification of beneficial owners, or an explanation of the activity that triggered the review.

Enhanced checks are not a judgement about you. They are the mechanism by which unusual but entirely legitimate situations are documented, so that they never become a problem for you later.

8. How long verification takes

A straightforward submission with clear documents is normally verified within one working day, and often within hours, since the first pass is automatic. Manual review extends the timeline where documents are ambiguous, where the file is selected randomly for quality control, or where enhanced due diligence applies; in those cases the process typically completes within three working days of receiving everything needed.

The status screen always shows which stage your file is at, and support can tell you whether anything is outstanding.

9. Why verification can be declined or paused

A file may be rejected or suspended for reasons including: documents that are expired, damaged or unreadable; details that do not match across documents; suspicion of alteration; a liveness check that cannot be completed; failure to provide requested supplementary information within the stated time; or an applicable legal restriction on opening the relationship. Where the reason can lawfully be shared, it is, together with the option to submit corrected documents and try again.

Funds already deposited into an unverified account are returned to their source by the same route they arrived.

10. Monitoring of transactions

Activity is monitored on an ongoing basis against the profile of the client: deposit and withdrawal sizes and frequency, instruments traded, and patterns of behaviour. Where activity is materially inconsistent with the profile, we may seek an explanation, and where required we pause the functions concerned while the review concludes, including deposits or withdrawals in specific cases.

Monitoring looks for patterns, not for profits. Trading results, favourable or otherwise, are not by themselves an AML event; the movement of money is.

11. Your responsibilities as a user

You are responsible for providing accurate, current and genuine data and documents, and for updating your details when they change. Using the account in your own name only, and not on behalf of undisclosed third parties, is a condition of service. Providing false information can lead to suspension or termination of the account, the return of funds to source, and, where the law requires, reporting to the authorities.

The practical version is simple: give your real details, upload your real documents, and answer compliance questions honestly and promptly.

12. Storage and protection of data

Identity documents and verification records are stored in encrypted, access-controlled systems with access limited to the compliance function and audited individually. Retention periods follow legal requirements: verification records are kept for the period required by applicable UK rules after the end of the relationship, after which they are securely destroyed. The handling of all personal data, including your rights over it, is described in the Privacy Policy.

13. Who data can be shared with

To operate verification and monitoring, data is shared with defined categories of recipients: identity verification providers, IT service providers under contractual confidentiality, affiliated companies within the group where they operate part of the service, and regulators or competent state authorities where a lawful request or reporting duty applies. Sharing is limited to what each purpose requires, and every recipient category is bound by data protection obligations.

14. Compliance with applicable requirements

Luminvestry conducts its activity with regard to the anti-money laundering and counter-terrorist financing requirements applicable in the United Kingdom, including those relating to customer due diligence, ongoing monitoring, record keeping and the reporting of suspicious activity. Where a service is delivered with a licensed partner, the applicable requirements of that partner's regulatory framework are observed alongside our own procedures.

15. Contact for KYC and AML questions

Questions about verification, documents or any part of this policy are answered by the compliance desk at [email protected]. If your question concerns a specific file, include the email address of your account so we can locate it quickly and answer precisely.