Compliance Statement
Direct Onboarding Only (No Third-Party Submission or Representation)
1. Definitions
1.1 “Lumonex” shall mean Lumonex LLC, and shall include its directors, officers, employees, and duly authorized agents.
1.2 “Client” shall mean the individual or legal entity submitting an application to onboard with Lumonex.
1.3 “Third Party” shall mean any individual or entity other than: (a) the Client (if an individual), or (b) the Client’s own bona fide internal personnel (e.g., directors, officers, or employees) acting within the scope of their employment for the Client. For the avoidance of doubt, “Third Party” includes, but is not limited to, consultants, introducers, company formation agents, corporate service providers, accountants, legal counsel, brokers, secretaries, “document runners,” and any other external representatives.
1.4 “Authorized Signatory” shall mean an individual designated by the Client and accepted by Lumonex as authorized to act on behalf of the Client, provided such individual is an internal director, officer, or employee of the Client.
2. Direct Client Relationship Requirement
2.1 Lumonex accepts Clients for onboarding exclusively on a direct basis. The Client acknowledges and agrees that the entire onboarding process, including all Know Your Client (KYC) verification, document submissions, confirmations, declarations, and related communications, must be carried out directly by the Client through its Authorized Signatory(ies).
2.2 Lumonex shall not accept any onboarding instructions, representations, or submissions made by any Third Party, regardless of whether such involvement is disclosed or undisclosed.
3. Prohibition on Third-Party
Document Preparation, Submission, and Representation
3.1 The Client is strictly prohibited from appointing, using, or permitting any Third Party to: (a) submit or upload onboarding or KYC-related documents to Lumonex; (b) communicate with Lumonex on the Client’s behalf concerning onboarding, verification, or compliance matters; (c) attend calls or meetings as a representative of the Client; (d) negotiate any onboarding terms on the Client’s behalf; (e) provide nominee, stand-in, or fronting services; or (f) furnish false, misleading, or pre-packaged documentation or information to Lumonex.
3.2 Any emails, messages, document uploads, signatures, forms, declarations, or other communications originating from a Third Party (even if such party purports to act on the Client’s behalf) may be rejected by Lumonex without further review.
4. Authorized Contacts and Verification
4.1 The Client shall designate at least one Authorized Signatory and provide verifiable contact details, which may include a corporate email domain, direct telephone number, and any identity verification documentation as requested by Lumonex.
4.2 Lumonex reserves the right to require live verification procedures, which may include video or voice calls, knowledge-based authentication, or the submission of additional documentation, to confirm that the Authorized Signatory is acting directly and with legitimate authority.
4.3 Should Lumonex reasonably suspect the involvement of a Third Party in the onboarding process, Lumonex may require the Client to resubmit all onboarding information directly. Lumonex further reserves the right to restart the onboarding process at the Client’s expense, where applicable.
5. Client Warranties
The Client hereby represents, warrants, and undertakes that:
5.1 All information and documentation provided during the onboarding process are true, complete, and accurate, and have been submitted directly by the Client or its Authorized Signatory without any Third-Party submission or representation.
5.2 The Client is not utilizing any Third Party for the purpose of concealing beneficial ownership, control, source of funds or wealth, identity, residency, tax status, or any other material information relevant to the onboarding or KYC process.
5.3 The Client shall immediately notify Lumonex if any Third Party attempts to act on the Client’s behalf in connection with the onboarding process.
6. Lumonex’s Rights and Remedies
6.1 If Lumonex determines, in its sole and absolute discretion, that a Third Party has been involved in the submission, preparation, or representation during the onboarding process, Lumonex may, without incurring any liability: (a) decline to onboard the Client; (b) suspend or terminate the onboarding process immediately; (c) require additional verification and direct resubmission of all materials by the Client; and/or (d) report such suspicious activity to relevant regulatory or law enforcement authorities as required by applicable law.
6.2 To the extent permitted by applicable law, any fees paid in connection with the onboarding application may be non-refundable in the event of refusal or termination resulting from a breach of this section by the Client.
7. Indemnity
7.1 The Client agrees to indemnify, defend, and hold harmless Lumonex, its affiliates, and their respective directors, officers, employees, and agents from and against any and all losses, liabilities, penalties, costs, and expenses (including, but not limited to, reasonable legal fees and disbursements) arising out of, or relating to: (a) any breach of this “Direct Onboarding Only” section by the Client; (b) any involvement of a Third Party in the onboarding process; or (c) any false, misleading, or incomplete information or documentation submitted in connection with the onboarding application.
8. No Reliance on Introducers or Intermediaries
8.1 The Client acknowledges that Lumonex does not authorize any introducers, intermediaries, or other Third Parties to bind Lumonex or to act on Lumonex’s behalf with respect to the onboarding process.
8.2 Any private arrangements, agreements, or payments between the Client and any Third Party are strictly outside the scope of Lumonex’s responsibility. Lumonex shall not be liable for any disputes, fees, commissions, or losses arising from such arrangements.
9. Survival
9.1 The provisions of this section shall survive any refusal to onboard, suspension, or termination of the onboarding process.
Lumonex LLC is registered with the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") as a Money Services Business ("MSB").
Lumonex provides technology and payment services in partnership with licensed and regulated financial institutions. All financial services and custody of funds are performed by Lumonex's licensed banking partners in accordance with applicable laws.