AML & Sanctions Policy
This summary describes Lootrunners’ approach to anti-money-laundering (AML), counter-terrorist-financing, and sanctions compliance, and how responsibilities are shared with our regulated payment partners.
This is a tailored template and must be reviewed by a qualified attorney before publishing.
Commitment
Lootrunners is committed to preventing its platform from being used to facilitate money laundering, terrorist financing, sanctions evasion, or other financial crime. We maintain a risk-based program and work only with regulated partners who perform the licensed financial activities.
Roles & partners
Lootrunners provides workflow, records, and orchestration software and does not take possession or control of customer funds. Receipt, conversion, and transmission of funds — and the regulated AML obligations that attach to them — are performed by our regulated payment partners. We store the partner’s verification status and identifiers rather than acting as the financial institution.
Customer due diligence
Business verification (KYB) of agencies and identity verification (KYC) of recipients are performed by the applicable payment partner where required, including collection of beneficial-ownership and other information appropriate to the entity and transaction. Lootrunners surfaces required information and will decline or pause activity where verification is incomplete.
Sanctions screening
Recipients and payout destinations are screened against applicable sanctions lists, including those administered by the U.S. Office of Foreign Assets Control (OFAC). Consistent with OFAC guidance for virtual-currency businesses, we will not knowingly facilitate, directly or indirectly, transactions that are prohibited, and we apply controls to prevent payouts to restricted parties or jurisdictions.
Transaction monitoring
We apply controls designed to detect unusual or higher-risk activity — including new or changed payout destinations, velocity and limit thresholds, and chain or network mismatches — and route flagged activity to a manual compliance queue for review. We may hold, delay, decline, or reverse activity, or request additional information, where risk is identified.
Reporting
Where regulatory reporting (such as suspicious-activity reporting) is required, it is filed by the responsible regulated party in accordance with applicable law. Lootrunners cooperates with lawful requests from regulators and law enforcement and supports partners with the records needed to meet their obligations.
Recordkeeping
We retain engagement, approval, payout, and audit records, and partner verification identifiers, for the periods required by applicable law and our partners’ requirements. Our internal ledger is append-only, and every sensitive action is written to an immutable audit log.
Governance & training
Responsibility for this program sits with Lootrunners’ compliance function, with oversight from management. Personnel in relevant roles receive training appropriate to their responsibilities, and the program is reviewed periodically and updated as regulations, partners, and risks change.
Contact
Compliance questions can be directed to our team.
Lootrunners, Inc. · Chicago, IL · [email protected]