Anti-Money Laundering (AML) & Counter-Terrorist Financing (CFT) Policy

1. Purpose

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Policy describes the standards and controls used by www.loot-hub to prevent, detect, and report money laundering, terrorist financing, proliferation financing, fraud, and related financial crime.

2. Scope

This Policy applies to www.loot-hub products, services, personnel, contractors, agents, and relevant third parties, and to users interacting with the platform, subject to applicable law.

3. Key Definitions

• Money laundering: concealing or disguising criminal proceeds.
• Terrorist financing: providing or collecting funds to support terrorist acts or organizations.
• Proliferation financing: financing weapons-of-mass-destruction proliferation.
• CDD/KYC: customer identification, verification, and risk assessment.
• EDD: additional due diligence for higher-risk customers, transactions, products, or regions.
• PEP: a person entrusted with prominent public functions, including relevant family members and close associates.

4. Regulatory Framework

LONTU COMPANY LIMITED seeks to comply with applicable Hong Kong AML/CFT requirements, relevant sanctions obligations, and internationally recognized Financial Action Task Force (FATF) standards. Where standards conflict, the stricter lawful requirement may be applied.

5. Risk-Based Approach

• Assess customer, product, transaction, delivery-channel, and geographic risk.
• Review the risk assessment periodically and after material service or market changes.
• Apply controls, limits, verification, monitoring, and review proportionate to identified risk.

6. Governance & Responsibilities

• Management approves the framework, risk appetite, oversight, and resources.
• The responsible compliance function manages controls, investigations, reporting, and regulatory liaison.
• Personnel must complete training, follow procedures, and escalate concerns promptly.

7. Customer Due Diligence

• CDD may be required at onboarding, when risk thresholds are reached, when information changes, or when suspicion arises.
• Individuals may be asked for name, date of birth, nationality, address, and government-issued identification.
• Organizations may be asked for registration, address, directors, authorized representatives, business purpose, and beneficial ownership information.
• Service may be declined or suspended if required CDD cannot be completed.

8. Enhanced Due Diligence

• Obtain additional information and, when appropriate, management approval for high-risk relationships.
• Assess and corroborate source of funds or source of wealth when warranted.
• Apply tighter limits, more frequent review, and closer monitoring to higher-risk activity.
• Perform appropriate PEP, sanctions, and adverse-media screening.

9. Ongoing Monitoring & Screening

• Monitor activity against expected behaviour and risk profile.
• Screen relevant persons and transactions against current sanctions, PEP, and watch lists.
• Investigate alerts, document decisions, and update customer information on a risk basis.

10. Transaction Controls

• Apply risk-based purchase, redemption, refund, and transaction limits.
• Restrict transactions involving sanctioned persons, prohibited regions, or unacceptable risk.
• Use payment, device, IP, velocity, and—where relevant—virtual-asset risk signals.
• Pause, decline, or request verification for transactions presenting red flags.

11. Suspicious Activity Reporting

Potentially suspicious activity is escalated confidentially to the responsible compliance function. Where required, reports are submitted to the competent authority without tipping off the affected customer.

12. Record Keeping

CDD, transaction, screening, alert, investigation, reporting, and training records are retained securely for the period required by applicable law and made available for lawful audit or regulatory requests.

13. Training & Awareness

Relevant personnel receive role-appropriate AML/CFT training at onboarding and periodically thereafter. Higher-risk functions receive additional targeted training.

14. Independent Review

The AML/CFT framework may be independently tested periodically and following material changes. Findings are documented and remediated in a timely manner.

15. Data Protection & Privacy

Personal data used for AML/CFT is processed for lawful, defined purposes with appropriate technical and organizational safeguards, consistent with the Privacy Policy and applicable law.

16. Third-Party Reliance

Where permitted, www.loot-hub may use regulated or assessed third parties for elements of identity verification, screening, monitoring, or payment risk control. LONTU COMPANY LIMITED retains responsibility for its compliance obligations.

17. Prohibited & Restricted Activity

• Services are unavailable where providing them would breach sanctions or applicable law.
• Prohibited uses include fraud, ransomware, darknet activity, human trafficking, child exploitation, weapons proliferation, obfuscation of criminal proceeds, and other illegal conduct.
• Relationships presenting unacceptable or unmanageable risk may be declined or terminated.

18. Sanctions Compliance

• Screen relevant parties and transactions against applicable UN, OFAC, EU, UK, Hong Kong, and other required sanctions lists.
• Block, reject, freeze, or report matches when required by law.
• Do not permit users to circumvent geographic or sanctions controls.

19. Breach & Enforcement

Policy violations may result in access restrictions, account termination, disciplinary action, partner termination, retention of relevant records, or reporting to authorities, as applicable.

20. Policy Review

This Policy is reviewed periodically and after significant regulatory, risk, product, or business changes. Material updates require appropriate approval.

21. Contact

Questions about this Policy or reports of suspicious activity may be sent to support@loot-hub.com.

RM1101, 11/F, SAN TOI BLDG, NO. 139 CONNAUGHT RD CENTRAL, HONG KONG

22. Disclaimer

This public Policy is a general overview of the www.loot-hub AML/CFT framework. It may be supplemented by confidential procedures, does not create a private right of action, and is not legal advice.