AML & KYC Policy
LumoVibe Media is committed to preventing money laundering and terrorist financing through robust identity verification and ongoing monitoring of all publisher relationships.
KYC Requirements
All publishers must complete our Know Your Customer (KYC) verification process before being onboarded. The following documentation is required:
Government-Issued Photo ID
A valid, unexpired government-issued identification document such as a passport, national ID card, or driver's license. The document must clearly display the publisher's full legal name, photograph, and date of birth.
Proof of Address
A recent document (issued within the last 90 days) confirming the publisher's residential or business address. Acceptable documents include utility bills, bank statements, or government-issued correspondence.
Business Registration Documents
If the publisher operates as a business entity, official registration documents are required. This includes articles of incorporation, business licenses, or equivalent documentation from the relevant jurisdiction.
Tax Identification Number
A valid tax identification number (TIN) or equivalent issued by the publisher's country of tax residence. For US-based publishers, this includes SSN or EIN. For international publishers, the local equivalent TIN is required.
All submitted documents are verified against original sources where possible. Incomplete or unverifiable submissions will result in onboarding delays until satisfactory documentation is provided.
AML Screening
As part of our anti-money laundering compliance program, all publishers undergo screening against relevant sanctions and watchlists during onboarding and on an ongoing basis.
OFAC/SDN List Screening
All publishers and their beneficial owners are screened against the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) list. Matches result in immediate rejection of the application and reporting to relevant authorities as required by law.
PEP Screening
Publishers are screened against Politically Exposed Persons (PEP) databases to identify individuals who hold or have held prominent public positions. PEP matches trigger enhanced due diligence procedures, including additional documentation requirements and senior management review before onboarding approval.
Ongoing Monitoring
KYC/AML compliance is not a one-time event. LumoVibe Media conducts ongoing monitoring to ensure continued compliance throughout the publisher relationship.
Periodic Re-Verification
Publisher identity and documentation are subject to periodic re-verification. The frequency of re-verification is determined by the publisher's risk profile:
- Standard risk: Re-verification every 24 months
- Elevated risk: Re-verification every 12 months
- High risk: Re-verification every 6 months or as needed
Transaction Monitoring
All financial transactions between LumoVibe Media and publishers are monitored for patterns indicative of potential money laundering or other illicit activity. This includes monitoring for unusual payment patterns, rapid changes in transaction volumes, and transactions involving high-risk jurisdictions.
Suspicious Activity Handling
When suspicious activity is identified, LumoVibe Media follows a structured review and reporting process.
Detection & Escalation
Suspicious activity is flagged by automated monitoring systems or staff and escalated to the compliance team for review.
Account Review
The publisher's account is placed under enhanced review. Campaign operations and revenue share payments may be temporarily suspended pending investigation.
Investigation
The compliance team conducts a thorough investigation, including review of transaction history, traffic data, and identity documentation.
Reporting
If the investigation confirms suspicious activity, LumoVibe Media files reports with relevant authorities as required by applicable law, including Suspicious Activity Reports (SARs) where mandated.
Resolution
Based on investigation findings, the publisher's account is either reinstated with enhanced monitoring, subject to additional restrictions, or permanently terminated.
Regulatory Compliance
LumoVibe Media's AML/KYC program is designed to comply with applicable US federal and state regulations, including:
- The Bank Secrecy Act (BSA) and its implementing regulations
- OFAC sanctions requirements
- FinCEN guidance applicable to money services businesses and related entities
- State-level AML/KYC requirements in jurisdictions where LumoVibe operates
Our compliance program is reviewed and updated periodically to reflect changes in regulatory requirements and industry best practices. All staff involved in publisher onboarding and account management receive regular training on AML/KYC procedures and obligations.