Draft — pending legal review

LAC maintains a risk-based anti-money laundering and counter-terrorist financing programme designed to prevent misuse of its invitation-only platform. This policy outlines customer due diligence, monitoring, reporting, and governance controls applicable to Token flows and connected venue activity.

This document is provided for informational purposes and remains subject to revision following counsel review. For questions regarding these policies, please contact legal@lac.com.

LAC's AML framework is calibrated to the nature of its infrastructure services, cross-ecosystem connectivity, and institutional client base. A designated compliance function oversees policy implementation, periodic risk assessment, and board or senior management reporting as defined in internal governance charters.

The programme aligns with applicable FATF-style recommendations and local regulatory expectations where LAC operates or onboard clients. Policies apply to employees, contractors, and appointed agents with access to customer or transaction data.

All clients undergo identity verification and risk scoring prior to full platform access. Standard due diligence collects identification, beneficial ownership, and purpose-of-relationship information; enhanced due diligence applies to higher-risk jurisdictions, complex structures, or unusual Token top-up patterns.

Ongoing due diligence includes periodic review of KYC freshness, material change notifications, and re-verification triggers such as large withdrawals, mandate changes affecting high-risk corridors, or adverse media hits screened through approved vendors.

Automated and manual monitoring review Token purchases, conversions, withdrawals, and patterns indicative of structuring, rapid in-out flows, or inconsistent activity relative to stated profile. Alerts are triaged by trained analysts according to documented escalation matrices.

Connected venue activity may be correlated where data is available through API telemetry or client disclosures. Monitoring rules are updated as typologies evolve and as regulatory guidance on digital assets and prediction-market flows matures.

Clients, beneficial owners, and relevant payment counterparties are screened against consolidated sanctions, PEP, and adverse media lists at onboarding and on a periodic or trigger basis. Matches are investigated before access is granted or transactions released.

LAC blocks or freezes activity where legally required and maintains audit logs of screening decisions. Clients must not use the platform to circumvent sanctions programmes of the United Nations, OFAC, EU, UK, or other applicable regimes.

Where internal investigation supports a reasonable suspicion of money laundering, terrorist financing, or sanctions evasion, LAC files reports with the appropriate financial intelligence unit or regulator in accordance with legal timelines and confidentiality provisions.

Employees and contractors are trained to recognise red flags and to escalate concerns without tipping off subjects where prohibited. Retaliation against good-faith reporting is not permitted under internal conduct standards.

KYC files, monitoring alerts, investigation notes, and STR filings are retained for periods mandated by applicable law, typically not less than five years after relationship termination unless longer retention is required. Records are stored with access controls and encryption consistent with the Privacy Policy.

AML training is provided at onboarding and refreshed on a regular cycle for all personnel in client-facing, engineering, and operations roles. Policy updates are communicated through internal channels and acknowledged by affected staff.