AML & KYC

Applies to all services provided by Lux Telecom. If you have bought service from us, the version in force is the one published on the date of your order. Contact us with any question about this document.

Wholesale voice carries real money-laundering and fraud risk: traffic can be manufactured, revenue can be shared with the terminating party, and prepaid balances can be used to move value. These are the controls we apply.

1. Our approach

We operate a risk-based programme: we identify who we are dealing with, understand the traffic they intend to send, monitor what they actually send, and act when the two diverge. Controls are proportionate to risk rather than uniform.

2. Customer due diligence

Before service is provisioned we identify and verify the legal entity, its registered address, its directors, and any beneficial owner holding 25% or more. We confirm that the person opening the account can bind the entity, and we verify ownership of the payment instrument. Details are in the verification policy.

3. Enhanced due diligence

We apply enhanced measures, including senior sign-off and closer monitoring, where risk is elevated: opaque ownership structures; a politically exposed person among owners or controllers; establishment in a jurisdiction identified as high risk or subject to heightened monitoring; requests concentrated on premium-rate or high-cost destinations; or a traffic profile inconsistent with the business described to us.

4. Sanctions and screening

We screen counterparties, their owners and controllers against applicable sanctions and restricted-party lists at onboarding and on an ongoing basis. We do not provide service where doing so would breach sanctions, and we will freeze or terminate service where a match is confirmed.

5. Ongoing monitoring

We monitor traffic and payment behaviour for indicators including sudden volume changes, concentration on high-payout destinations, short-duration high-volume patterns consistent with artificially inflated traffic, calling patterns consistent with Wangiri, mismatch between registered origination points and observed signalling, and payment patterns inconsistent with the stated business. Automated caps and alerts back this up.

6. Source of funds

We may ask about the source of funds where the amount or pattern of payment warrants it. Refunds are made only to the original source of funds. We do not accept payment from, or refund to, a third party unconnected to the account.

7. Record keeping

We keep verification records, the evidence supporting them, and records of our monitoring decisions for the period required by the applicable anti-money-laundering law following the end of the relationship. Handling of that data is described in our privacy policy.

8. Reporting and confidentiality

Where we are required to report a suspicion to the competent authority, we will do so. Where the law prohibits us from telling you that a report has been made, we will not tell you, and we will not give a misleading explanation instead: we will decline to comment. We may suspend or terminate service without a detailed reason where disclosure is legally restricted.

9. Your obligations

You must keep the information you have given us current, tell us about a change of control or of beneficial ownership, apply equivalent diligence to your own customers where you resell our service, and cooperate with reasonable requests for information during an investigation. Failure to do so is a ground for suspension under the terms of service.