AML Policy

Luca Investment Strategic Sp. z O.O., reg. number LLC23233, authorised to provide virtual currency service, with registered and operational address at 86 Hoża street, Unit 210, Warsaw, Postcode 00-682, Poland (hereinafter also as “us,” “we” and in case of relation tous – “our”), which provides Services through sereneswap.com (the Website) and/or mobile application (collectively or individually “The Platform”).

The objective of the AML policy

Luca Investment Strategic Sp. z O.O. is under the obligation to apply anti-money laundering (AML) requirements in our business. All our staff are committed to pursuing the highest standards of AML and Know Your Customer (KYC) compliance to mitigate the risk of our services being used to facilitate financial crimes.

We have implemented the framework of AML Policy in order to ensure that all the necessary steps are taken to achieve the full safety of our services. In this AML Policy, we are committed to following the provisions specified in Lithuania AML laws and EU and international AML guidelines.

What is AML policy?

AML Policy is the procedure to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements. KYC measures are part of the AML Policy. KYC measures aim to enable businesses to know and understand their customers better and help them manage their risks. Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable European and International regulations.

They will be reviewed and updated on a regular basis to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.

In case of any potentially suspicious or unusual transactions or customer behaviour, we undertake appropriate measures to address the risks. All staff handling transactions may ask for additional documents, such as proof of source of funds, etc., as deemed appropriate.

We keep a well-organised procedure for maintaining all records, including customer identification documents and related data. All customer and transactional information is stored confidentially and according to personal data protection laws.

Our AML policy includes:

Establishing robust internal policies, procedures, and controls that combat any attempt to use us for illegal or illicit purposes and are designed to ensure our customers’ basic protections under consumer protection laws.

Employing an AML/CFT Compliance officer to be responsible for our AMC/CFT procedures.
Performing an internal and independent audit of our/CFT policies annually.
Identification and verification of the customer before entering a financial business relationship with us.
Establishment and maintenance of risk-based customer due diligence, including enhanced due diligence for those customers presenting higher risks.
Transactions monitoring of the customer financial behaviour based on risk-based analysis.
Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities.
Periodical AML training for our staff.

We are obligated to reject the customer’s documents, close the account, and terminate the business relationship if we find any suspicious activity, false documents, or non-cooperation by the customer within the customer’s due diligence process.

Sanctioned countries

In accordance with our policies, we do not open accounts when your trade volume rises. Our AML / CTF verification duties increase as well. The same happens when your transactions are “flagged” as suspicious or unusual, or our verification of your personal results in qualifying you as a person imposing significant AML / CTF risk. And do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations or countries based on various criteria selected by our AML team (for example, Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission)impose high AML / CTF high risk.

Currently, these countries are:

Afghanistan, Albania, Algeria, Bahamas, Barbados, Belarus, Bosnia and Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cayman Islands, Central African Republic, China, Congo, Cuba, Democratic Republic of Congo, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guinea Bissau, Haiti, Iran, Iraq, Israel, Jamaica, Japan, Jordan, Kyrgyzstan, Lebanon, Libya, Mali, Malta, Maynmar, Morocco, Mozambique, Niger, Nigeria, Nicaragua, Pakistan, Palestine Territory, Panama, Philippines, Puerto Rico, Russia, Senegal, Serbia, Somalia, South Sudan, Sudan, Saudi Arabia, Syria, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, Uzbekistan, United States, Venezuela, Virgin Islands U.S., Yemen, Zimbabwe.