# Intro

**Founded in 2021, LOTUS is a fintech initiative focused on providing a hybrid finance solution that combines the benefits of decentralization with regulatory compliance, ensuring alignment with the legislation of centralized governing bodies.**


# Vision

At **Lotus**, our vision is to create a world where financial access is **borderless, inclusive, and effortless**. We aim to break the barriers between fiat and crypto, empowering individuals and businesses to **transact, save, and grow** without limitations.

We believe the future of finance is **global yet personal** — a system where you can move your money anywhere, in any currency, instantly and securely. Through **Lotus Now**, we are building the bridge between traditional banking and next-generation digital finance, ensuring that everyone — from freelancers to global enterprises — can participate in the economy without friction.

Our ultimate goal is to position Lotus as **the most trusted financial platform in the Middle East and beyond** by 2026, leading the way in innovation, compliance, and customer experience.

### Key takeaways

* **Hybrid crypto-fiat payments** powered by LOTUS CHAIN and LOTUS FINANCE services.
* First hybrid blockchain specially developed for the fintech sector.


# Ecosystem


# LOTUS FINANCE

Lotus Ecosystem

LOTUS FINANCE is our financial platform. The platform services vary from DEFI to CEFI services. And includes: 

* LightX - Crypto/Fiat Swaps.
* Lotus Cards - Crypto Virtual Cards for daily use and major expenses
* Giftyx - Gift card marketplace
* Lotus Internal transfers - Transactions via Lotus Payment Addresses

To be released 

* [LTS CCL](/v2-documentation/ecosystem/lotus-finance/roots-previously-ccl) - Decentralized on-chain verification service.
* Wizarda - Global payouts 
* HydraPad – Startup fundraising

More services to be announced in later phases.


# LightX

LOTUS FINANCE SERVICE

**LightX** is an e-currency exchange platform designed to bridge the gap between e-banks and traditional banks.

The platform supports **crypto/fiat instant swaps**.

#### <br>


# L-Banko

Lotus Finance Service

Fiat or crypto? Why not both? That’s our answer with our latest innovation: **L-Banko**.

**Hybrid USD/EUR accounts** for personal and business use.\
Receive funds in **USD or EUR** and settle into **7 different currencies.** including **USDT, USDC, and Bitcoin** in just a click.<br>

### Flow

<figure><img src="/files/M2k7dbITlsMKf6VbUeFd" alt=""><figcaption></figcaption></figure>

\
Account fees: [HERE](https://ltsfinance.com/fees)


# Microdeposits

### Overview

When a user sets up a **USD ACH Virtual Account** for bank withdrawals, they may be required to complete a **microdeposit verification** process to confirm ownership of the linked bank account.

Microdeposits, also known as **micro-entries**, are one or more small ACH credit transactions — and in some cases offsetting debits — sent by a financial institution or payment originator to verify that the customer owns and can access the target bank account. This is a standard banking and compliance procedure used during ACH account setup.

### Key Characteristics

* **Purpose:** Verify ownership of a bank account during ACH account linking
* **Appearance:** Microdeposits appear as small deposits in the user’s bank transaction history
* **Requirement:** Some banks require this step before ACH registration can be completed
* **Compliance:** This is a standard requirement for ACH transfer authorization and account validation

{% hint style="info" %}
Not all banks require microdeposit verification.
{% endhint %}

* **# Important Notes**

{% hint style="warning" %}
**Microdeposits are never onramped.** Any deposit under **$1.00** is treated as a verification attempt only and will **not** trigger a payment, transfer, or settlement.
{% endhint %}

{% hint style="info" %}
Unlike standard deposits, Lotus does **not** accumulate the balance of microdeposits. Once verification is complete, these amounts remain unprocessed.
{% endhint %}

* Additional notes:
* In most cases, microdeposit amounts fall below Lotus's fee threshold, so no output withdrawal is generated.
* **Only Virtual Accounts support microdeposit verification.**
* **Static memo-based deposit flows are not compatible** with this verification method.
* Each customer must have their own **individual Virtual Account** to complete the process.
* A microdeposit event may include the **amount**, **source bank details**, and **timestamp**. These details can be shown to customers for verification and transparency.

### Verification Process

1. The customer initiates linking their bank account to the assigned Virtual Account.
2. If required by the bank, one or more microdeposits are sent to the customer’s bank account.
3. The customer checks their bank transaction history to identify the deposit amount(s).
4. The customer enters the amount(s) into the verification interface.
5. Once the submitted values are confirmed successfully, the bank account is verified and linked.

   <div data-gb-custom-block data-tag="hint" data-style="success" class="hint hint-success"><p>After successful verification, the user’s <strong>USD ACH Virtual Account</strong> is fully activated and ready for use.</p></div>

### Conclusion

Microdeposit verification is a secure, industry-standard method for confirming ACH account ownership. Once the user successfully verifies the deposited amount(s), their **USD ACH Virtual Account** becomes fully verified and ready for transactions.


# Why was my foreign (USD/EUR) virtual bank account request declined/taking too long to get approved?

#### 1. Unclear or Unreadable Document

We must be able to clearly verify your identity. If the document on file is blurry, poorly lit, cropped, submitted in black and white, or provided as a screenshot, your application may be declined.

**How to fix it:**\
Please contact Lotus Support and request access to re-upload a clear, high-quality, color photo of your original document. Make sure all details are fully visible and easy to read.

***

#### 2. Temporary or Unsupported Document

Temporary IDs, NIN slips, black-and-white scans, photocopies, or screenshots are not accepted for verification.

**How to fix it:**\
Please contact Lotus Support and request access to upload a valid, original identity document, such as:

* National ID
* Passport
* Driver’s license
* Voter’s card

Make sure the document is submitted as a clear, high-quality color photo.

***

#### 3. Restricted Country

Due to regulatory and compliance requirements, Lotus is unable to provide USD or EUR bank accounts in certain countries read [Restricted Geos](/v2-documentation/ecosystem/lotus-finance/l-banko/l-banko-restricted-geos).

***

#### 4. Altered or Edited Document

For security and compliance reasons, any document that appears to be edited, modified, or tampered with cannot be accepted.

***

#### 5. Expired Document

Your identity document must be valid at the time of submission. Expired documents cannot be accepted.

***

#### Need More Help?

Our support team is always ready to assist you.

Contact us at **<support@ltsfinance.com>**\
Or open the Lotus app and go to **Account > Support** to chat with support directly.

With a valid and clearly submitted identity document, your application can be reviewed smoothly for seamless international transactions.


# Guardrails


# GBP Accounts

* M**inimum £3.00 GBP**

* No maximum, transfers received or sent over £1M GBP will use the BACS payment rail.

* 1st and 3rd party payouts supported

* 1st party payins supported, 3rd party payins supported from businesses.

* Faster Payments complete in \~5 minutes however may take up to 30 minutes for larger values.

* BACS payments complete in 3 business days.

<br>


# EUR Accounts

#### EUR Virtual Accounts <a href="#eur-virtual-accounts" id="eur-virtual-accounts"></a>

**Receive First-Party Deposits from**

* The customer’s **own** bank, fintech app, or brokerage account.

**Receive Third-Party Deposits from**

* **Registered businesses** sending EUR from a domestic business account
* A **close friend or family member’s** bank account

**Limits**

* **Single-transaction limit:** **15 000 EUR** — any transaction that exceeds this limit **triggers an Enhanced Due Diligence (EDD) review**.
* **Monthly aggregated limit:** **30 000 EUR** — the transaction that pushes a customer over this volume **triggers an EDD review**.

<br>


# USD Accounts

#### USD Virtual Accounts <a href="#usd-virtual-accounts" id="usd-virtual-accounts"></a>

**Non-US-Resident Customers**

**Receive First-Party Deposits from**

* The customer’s bank, fintech app, or brokerage account.

**Receive Third-Party Deposits from**

* **Registered businesses** sending USD from a domestic business account
* A **family member’s** bank account where the customer shares a surname
* **Non-family members** up to **5 000 USD** — any transaction that exceeds this limit **triggers an EDD review**

***

**US-Resident Customers**

**Receive First-Party Deposits from**

* The customer’s bank, fintech app, or brokerage account.

**Receive Third-Party Deposits from**

* **Registered businesses** sending USD from a domestic business account

***

**Limits (apply to all USD Virtual Accounts)**

* **Single-transaction limit:** **10 000 USD** — any transaction that exceeds this limit **triggers an EDD review**.
* **Monthly aggregated limit:** **20 000 USD** — the transaction that pushes a customer over this volume **triggers an EDD review**.

<br>

<br>


# Enhanced Due Diligence (EDD) Process

When an EDD review is triggered, Lotus Compliance team will request

* Purpose of the transaction
* Proof of Source of Funds (SoF)

*Deposits requiring EDD are frozen at the Fiat currency step until the requested information is received. Once EDD is completed, funds are unfrozen, converted to the defined cryptocurrency, and credited to customer's Lotus account. If the documents are not provided within **10 days** of the RFI, the transaction will be rejected and the funds automatically refunded.*

#### Important Note <a href="#important-note" id="important-note"></a>

Lotus reserves the right, at its sole discretion, to:

1. Request further information and/or documentation for any payment made by a third party; and
2. Amend and/or update these Guardrails from time to time.


# L-Banko Restricted Geos

Below is a list of countries with full or partial restrictions for L-Banko accounts.

### 📋 Overview

Each country is assigned a **Risk Tier** and a set of supported payment corridors:

| Symbol | Meaning       |
| ------ | ------------- |
| ✅      | Supported     |
| ❌      | Not supported |

#### Risk Tiers

| Tier             | Description                                          | Documents                                                                                                                                           |
| ---------------- | ---------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------- |
| 🟢 **Low**       | Standard processing, minimal compliance requirements | Full name, date of birth, nationality • Verified e-mail address                                                                                     |
| 🟡 **Medium**    | Medium compliance requirements                       | Full name, date of birth, nationality • Verified e-mail address                                                                                     |
| 🔴 **High**      | Additional documentation needed                      | <p>Government-issued photo ID (verified via liveness + OCR)</p><p></p><p>Proof of residential address ≤ 3 months old • Proof of source of funds</p> |
| ⛔ **Prohibited** | Applications not permitted                           | Applications not permitted                                                                                                                          |

***

### ⛔ Prohibited Countries

<table data-header-hidden="false" data-header-sticky><thead><tr><th>Country</th><th>USD</th><th>EUR</th><th>GBP (FPS)</th><th>USDBASE</th><th>EURBASE</th></tr></thead><tbody><tr><td>Afghanistan</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Belarus</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Congo, Democratic Republic of the</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Cuba</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Gaza Strip / West Bank</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Iran, Islamic Republic of</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Iraq</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Korea, Democratic People's Republic of</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Lebanon</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Libya</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Myanmar</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Russian Federation</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Somalia</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>South Sudan</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Sudan</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Syrian Arab Republic</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Ukrainian Territories (Crimea, Sevastopol, Donetsk, Kherson, Luhansk, Zaporizhzhia)</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Venezuela, Bolivarian Republic of</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Yemen</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr></tbody></table>

***

### 🟢 Low Risk Countries

<table data-header-hidden="false" data-header-sticky><thead><tr><th>Country</th><th>USD</th><th>EUR</th><th>GBP (FPS)</th><th>USDBASE</th><th>EURBASE</th></tr></thead><tbody><tr><td>Andorra</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Anguilla</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Australia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Austria</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Belgium</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bermuda</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bonaire, Sint Eustatius and Saba</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Canada</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Curacao</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Czechia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Denmark</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Estonia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Finland</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>France</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>French Guiana</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>French Polynesia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Germany</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Greenland</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Guadeloupe</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Guam</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Guernsey</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Iceland</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Ireland</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Japan</td><td>❌</td><td>❌</td><td>❌</td><td>✅</td><td>❌</td></tr><tr><td>Jersey</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Korea, Republic of</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Latvia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Liechtenstein</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Lithuania</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Luxembourg</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Martinique</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Mayotte</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Netherlands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>New Caledonia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>New Zealand</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Norway</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Poland</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Portugal</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Reunion</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Barthelémy</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Martin (French part)</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Pierre and Miquelon</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>San Marino</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Singapore</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Slovenia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Spain</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Sweden</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Switzerland</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Taiwan, Province of China</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>United Kingdom</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td><td>❌</td></tr><tr><td>Uruguay</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Wallis and Futuna</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr></tbody></table>

***

### 🟡 Medium Risk Countries

<table data-header-hidden="false" data-header-sticky><thead><tr><th>Country</th><th>USD</th><th>EUR</th><th>GBP (FPS)</th><th>USDBASE</th><th>EURBASE</th></tr></thead><tbody><tr><td>Albania</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>American Samoa</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Antigua and Barbuda</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Argentina</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Armenia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Aruba</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Azerbaijan</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Bahamas</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bahrain</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Belize</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bosnia-Herzegovina</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Botswana</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Brazil</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Brunei Darussalam</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Cayman Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Chile</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Colombia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Costa Rica</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Croatia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Cyprus</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Dominica</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Dominican Republic</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Ecuador</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Egypt</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>El Salvador</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Fiji</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Gambia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Georgia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Ghana</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Greece</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Grenada</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Guatemala</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Guyana</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Holy See</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Honduras</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Hong Kong</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Hungary</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>India</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Isle of Man</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Israel</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Italy</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Jordan</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Kazakhstan</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Kosovo</td><td>❌</td><td>✅</td><td>✅</td><td>❌</td><td>✅</td></tr><tr><td>Macao</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Malawi</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Malaysia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Malta</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Marshall Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Mauritius</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Mexico</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Micronesia, Federated States of</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Moldova, Republic of</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Mongolia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Montenegro</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Morocco</td><td>❌</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Nauru</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Niue</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>North Macedonia</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td><td>❌</td></tr><tr><td>Northern Mariana Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Oman</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Paraguay</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Peru</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Puerto Rico</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Qatar</td><td>❌</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Romania</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Rwanda</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Kitts and Nevis</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Lucia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Vincent and the Grenadines</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Samoa</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saudi Arabia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Serbia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Seychelles</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Sint Maarten (Dutch part)</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Slovakia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Timor-Leste</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Tunisia</td><td>❌</td><td>❌</td><td>❌</td><td>✅</td><td>❌</td></tr><tr><td>Turks and Caicos Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>United States</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Uzbekistan</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Virgin Islands (U.S.)</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Zambia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr></tbody></table>

***

### 🔴 High Risk Countries

<table data-header-hidden="false" data-header-sticky><thead><tr><th>Country</th><th>USD</th><th>EUR</th><th>GBP (FPS)</th><th>USDBASE</th><th>EURBASE</th></tr></thead><tbody><tr><td>Algeria</td><td>❌</td><td>❌</td><td>❌</td><td>✅</td><td>✅</td></tr><tr><td>Angola</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Antarctica</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bangladesh</td><td>❌</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Barbados</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Benin</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bhutan</td><td>❌</td><td>✅</td><td>✅</td><td>❌</td><td>✅</td></tr><tr><td>Bolivia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bouvet Island</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>British Indian Ocean Territory</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Bulgaria</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Burkina Faso</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Burundi</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Cabo Verde</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Cambodia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Cameroon</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Central African Republic</td><td>✅</td><td>❌</td><td>❌</td><td>✅</td><td>❌</td></tr><tr><td>Chad</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>China</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Christmas Island</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Cocos (Keeling) Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Comoros</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Congo</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Cook Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Cote d'Ivoire</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Djibouti</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Equatorial Guinea</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Eritrea</td><td>✅</td><td>❌</td><td>❌</td><td>✅</td><td>✅</td></tr><tr><td>Eswatini</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Ethiopia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Falkland Islands (Malvinas)</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Faroe Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>French Southern Territories</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Gabon</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Gibraltar</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Guinea</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Guinea-Bissau</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td><td>❌</td></tr><tr><td>Haiti</td><td>❌</td><td>✅</td><td>✅</td><td>❌</td><td>❌</td></tr><tr><td>Heard Island and McDonald Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Indonesia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Jamaica</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Kenya</td><td>❌</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Kiribati</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Kuwait</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Kyrgyzstan</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Lao People's Democratic Republic</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Lesotho</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Liberia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Madagascar</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Maldives</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Mali</td><td>✅</td><td>❌</td><td>❌</td><td>✅</td><td>❌</td></tr><tr><td>Mauritania</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Monaco</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Montserrat</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Mozambique</td><td>❌</td><td>✅</td><td>✅</td><td>❌</td><td>❌</td></tr><tr><td>Namibia</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Nepal</td><td>❌</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Nicaragua</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td><td>❌</td></tr><tr><td>Niger</td><td>❌</td><td>✅</td><td>✅</td><td>❌</td><td>✅</td></tr><tr><td>Nigeria</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Norfolk Island</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Pakistan</td><td>❌</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Palau</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Panama</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Papua New Guinea</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Philippines</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Pitcairn</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Helena, Ascension and Tristan da Cunha</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Saint Kitts and Nevis</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Sao Tome and Principe</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Senegal</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Sierra Leone</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Solomon Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>South Africa</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>South Georgia and the South Sandwich Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Sri Lanka</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Suriname</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Svalbard and Jan Mayen</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Tajikistan</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Tanzania, United Republic of</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Thailand</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Togo</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Tokelau</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Tonga</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Trinidad and Tobago</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Turkey</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Turkmenistan</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Tuvalu</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Uganda</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Ukraine</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td><td>❌</td></tr><tr><td>United Arab Emirates</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>United States Minor Outlying Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Vanuatu</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>❌</td></tr><tr><td>Vietnam</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Virgin Islands (British)</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Western Sahara</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr><tr><td>Zimbabwe</td><td>❌</td><td>✅</td><td>✅</td><td>❌</td><td>❌</td></tr><tr><td>Åland Islands</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td><td>✅</td></tr></tbody></table>

***

**USD accounts are US-based.**\
**GBP accounts are UK-based.**\
**EUR accounts may be based in Malta, Lithuania, or Germany, depending on the applicant’s country and risk tier.**


# Prohibited activities

The following business sectors are not permitted regardless of risk tier or country. Reject any customer — individual or corporate — who is active in these areas.

* Adult entertainment (creating, distributing, or providing)
* Gambling (casinos, sports betting, etc.)
* Exotic animals trade
* Diamond industry
* Arms industry and dual-use goods
* Piracy or illegal streaming
* Counterfeit goods
* Unregulated pharmaceuticals and food supplements (e.g. nutraceuticals)
* Crypto-related:
  * Facilitating the exchange of anonymous cryptocurrencies
  * Unlicensed facilitation of security tokens
  * Binary options
  * Unlicensed FX brokers
* Unlicensed charities
* Third-party payments and multi-layered MBS arrangements
* Hawala

<br>


# Wasla

Lotus Finance Service

No matter where you are, Money-zatak always **Wasla**.\
Global payouts with Crypto&#x20;

* [x] More than 110 active bank rails worldwide&#x20;
* [x] Fund your payouts using **crypto or fiat**&#x20;
* [x] Supports banks and wallets.


# Lotus Cards

Lotus Finance Service

### One card for all expenses

* Real-time spending tracking
* Instant issuance — use online or globally
* 3DS Support
* Instant top-up via crypto or fiat
* Apple Pay / Google Pay support
* Global acceptance

Fees are available [HERE](https://ltsfinance.com/fees)


# Neufero X (Virtual)


# Neufero X (Usage policy)

This policy is only implemented on virtual Neufero X cards\ <br>

1. 8 consecutive declined transactions due to insufficient funds will result in card termination.
2. Using the card only for free-trial subscriptions is prohibited and will result in card termination
3. Sharing card details is prohibited and will result in card termination&#x20;
4. If the card’s Grand Cash balance drops below -5,000, the card will be terminated. (-5000 grand cash balance is a -5,000 USD in declined transactions without any spending) refer to Grand cash to understand how it works


# Restricted MCCs

### Unsupported Merchant Categories for Neufero X

Neufero X may be declined or restricted when used with merchants classified under the following MCC codes. These categories are considered unsupported based on compliance restrictions.

| MCC Code | Category Description                                                                           | Sample Merchants                   |
| -------- | ---------------------------------------------------------------------------------------------- | ---------------------------------- |
| 4829     | Money transfer services                                                                        | Wise, MoneyGram                    |
| 5966     | Direct marketing via outbound telemarketing                                                    | Telemarketing companies            |
| 6051     | Foreign currency, cryptocurrency, money orders, travelers cheques, and debt repayment services | Coinbase, Luno, Binance            |
| 6211     | Securities brokers and dealers                                                                 | Investment companies               |
| 7273     | Dating services                                                                                | Tinder, Badoo                      |
| 7297     | Massage parlors                                                                                | Thai-Me Spa                        |
| 7800     | Government-owned lottery services (US only)                                                    | California Lottery                 |
| 7801     | Government-licensed online gambling services (US only)                                         | DraftKings, FanDuel                |
| 7802     | Government-licensed horse and dog racing services (US only)                                    | Churchill Downs, Santa Anita Park  |
| 7995     | Betting and gambling-related services                                                          | Bet9ja, Merrybet, 1Xbet, Sportybet |

> **Important:** If your transaction is declined because of a restricted Merchant Category Code (MCC), the rejection reason will be shown as **`Failed Control`**.\
> Please review the merchant’s MCC and confirm whether it falls under any of the restricted categories listed above. The MCC can be found in the transaction details within the app.


# Grand cash (Neufero X Cashbacks)

* Each **$1 USD** spent in a transaction earns **+1 Grand Cash point**
* Each **$1 USD** attempted in a **declined** transaction results in **-1 Grand Cash point**
* Every 2,500 Grand Cash points can be redeemed for $25 USD through our Web, Android, and iOS apps.

{% hint style="info" %}
If the card’s Grand Cash balance drops below -5,000, the card will be terminated.
{% endhint %}


# Neufero X (3DS)

Below is a short video showing how to approve 3DS on your Neufero X card.

{% embed url="<https://cdn.ltsfinance.com/3DS_Approval.mp4>" %}


# Neufero Black X (Physical)

Limited edition Physical cards

{% hint style="info" %}
Card pre-orders will open soon.
{% endhint %}


# HydraPad

LTS FINANCE SERVICE

HydraPad is a decentralized launchpad on Lotus ecosystem. launchpad will feature new funding solution as well as tools for investors to help them finding out their next investment and expected return. More info about HydraPad will be announced in phase 2 roadmap.&#x20;


# Roots (Previously CCL)

Lotus Ecosystem

* LTS Clean Coin Listings is aiming to be the first blockchain scanner for verified addresses. The scanner will feature both contracts and wallet addresses.
* All listed addresses on the CCL must pass the listing audit, which will consist of KYC (know your customer) for personal wallets and a full project audit for contracts.
* [LTS CCL grading system (CGS)](/v2-documentation/ecosystem/lotus-finance/roots-previously-ccl/projects-verification/grading-system) will help investors identify the most suitable investment and the risks associated with it.
* LTS CCL is also featuring a scam addresses and a reporting system to help users detect fraud and scam addresses.
* With both benifits of CCL and CCAFP we will be able to help users detect scam and suspectious addresses and contracts on-chain and deliver the safe decentralization solution.


# Projects verification


# Projects verification procedures

### CCL Application

<figure><img src="/files/szaPM7o8mtOwX3dJRDms" alt=""><figcaption><p>CCL Application</p></figcaption></figure>

1. Full name of the project founder (Must be same as passport).
2. Email (Must be a business email eg.CEO\@Projectdomian).
3. Requested address will be assigned automatically after connecting your wallet.
4. Contract address of project token or the smart contract you wish to verify.
5. Chain which smart contract has been deployed.

### Documents uploading

After applying applicant will get a success message and application id as well as an email to schdule meeting date as well as a link where applicant will upload

* A scanned copy of applicant passport.
* Project links (including social platforms links).
* Project whitepapers.
* Token vesting schdule (If available).
* Previous security audits (If available).

Please note: In this step we will evaluate your project by our [criteria ](/v2-documentation/ecosystem/lotus-finance/roots-previously-ccl/projects-verification/grading-system)if the project passed we will get to the third step, If the project did not meet our criteria we will refund the paid amount to the sender's wallet, Check [refunds](/v2-documentation/ecosystem/lotus-finance/roots-previously-ccl/projects-verification/service-fees#refunds).&#x20;

### Meeting

Third step is a meeting between between our team and project founder to discuss project technicalities and all informations.

* Meetings are held on English mainly, We also supports Arabic and we will supports more in the upcoming future (For Arabic meetings please specify on email while doing previous step).
* Note that our agent may ask to take a screenshot of the meeting or applicant while holding the passport.
* All meetings are being held on Zoom.

If applicant is having any issue with the previous steps, Contact [@mks3lim](https://telegram.me/mks3lim).

### Listing

After completing all the steps above project will be graded and listed on CCAFP and CCL scanner (Listings usually takes between 24-48 hours).


# Service Fees

* Fees for project application are 2 BNB or 50,000 LTS (25% lesser than BNB). &#x20;

### Refunds

We make sure that all projects meet our listing criteria, check our [criteria](/v2-documentation/ecosystem/lotus-finance/roots-previously-ccl/projects-verification/grading-system) before applying, If the project listing application got declined applicant will be refunded the paid amount - 10% (Reviewing fees).


# Grading system

Projects grading system runs through 6 main evaluation processes done by our team

* [Idea](#idea)
* [Team](#team)
* [Funding (for previously launched projects)](#funding-for-previously-launched-projects)
* [The ability of such idea to generate profit (Feasibility study)](#the-ability-of-such-idea-to-generate-profit-feasibility-study)
* [Project market capitalization (For previously launched projects)](#project-market-capitalization-for-previously-launched-projects)
* [Project token vesting schedule and allocations](#project-token-vesting-schedule-and-allocations)

### Idea

Our team evaluate the ability of the idea to compete in the market in order to provide the most profit for our investors. Our team also might offer an additional funding in highly competitive idea and provide the project with the necessary technology.

### Team

Our team evaluate the technical experience of the team in order to ensure that the project has the capacity to deliver the promised idea with the promised quality.

### Funding (for previously launched projects)

For previously launched projects, our team will ask for previous funding rounds. And how it was spent.

### The ability of such idea to generate profit (Feasibility study)

Our team will evaluate the idea capacity to compete in the market and the ability of the project to generate profit in order to ensure about the ability of the project to survive.

### Project market capitalization (For previously launched projects)

### Project token vesting schedule and allocations

### CGS (CCL grading system)

<figure><img src="/files/XJbgbD3hvy2lb4VscHMP" alt=""><figcaption><p>Lotus assets grading system</p></figcaption></figure>


# Wallets verification


# Wallets verification procedures

### CCL Application

<figure><img src="/files/0BxO0Rbo4jEXHHDnpIO1" alt=""><figcaption><p>CCL Wallet Application</p></figcaption></figure>

1. Full name of wallet owner (Must be same as passport).
2. Applicant email address.
3. Requested address will be assigned automatically after connecting your wallet.
4. Chain&#x20;

Note that specifing a chain for an ETH address will not take an effect as address will be verified across ETH and forks eg BNB, Polygon


# Service Fees

* Fees for wallet applications are 0.5 BNB or 5,000 LTS (25% lesser than BNB). &#x20;


# Deposits


# How to get transaction ID for fiat deposits

Transaction ID: An ID for a transaction generated by your payment provider. You can get the transaction ID for a specific transaction right after it is made. It is often called a transaction reference or transaction ID.

### Instapay (EGYPT) EGP Manual Deposits

<figure><img src="/files/DJed7oKoRMLb68J8d5TC" alt=""><figcaption></figcaption></figure>

### Vodafone Cash (EGYPT) EGP Manual Deposits

<figure><img src="/files/NfjX6rFn2Ed8XxDRgaE8" alt=""><figcaption></figcaption></figure>


# CCAF protocol checkers

LOTUS FINANCE SERVICE

Crosschain antifraud protocol checkers are an easy way to check for different addresses state on blockchain CCAF protocol checkers are&#x20;

* CCAF Verified addresses checker.
* CCAF Suspected addresses checker. (LTS Holders)
* CCAF Scam addresses checker.
* CCAF Ongoing request addresses checker for ongoing applications. (LTS Holders)

LTS Holders privileges requires a minimum balance of LTS to be available on requester wallet during the check (No LTS will be deducted).

More info about CCAF will be announced in phase 2 roadmap


# CCAF (Crosschain antifraud) protocol

LTS CCL SERVICE

### Intro

Crosschain antifraud protocol (CCAFP) is the solution to eliminate fraud activities and illegal behaviours that can be caused by Web3 decentralization&#x20;

We believe that full decentralization is the main obstacle for governors to adopt crypto technology, and we understand that full decentralization and full crypto adoption may lead to

* Money laundering.&#x20;
* Inability to recover lost or stolen assets.
* Illegal transactions and payments.

Relying on an organizational protocol will help DEFI users to protect their assets as well as increasing Crypto adoption rate.

### How it works

CCAFP is a set of blockchain smart contracts that is used to verify wallets and smart contracts. The main idea about CCAFP is to develop an orgnaizational smart contract that act as public database. Data on CCAFP smart contract is immutable except the address/contract state. We believe that address state must be modifiable to be able to change scam address states if they were verified before.


# Reporting

* Users can report projects and wallets on the CCL by contacting [reports@ltsccl.com](mailto:repots@ltsccl.com)

### Required data

Reporting a listed address on the CCL requires the following

* Address/Contract address.
* Reasonable evidence where the reported address is clearly involved in a breach [read](/v2-documentation/important/handling-and-storing-data#breach-sanction).

Please note that if the reporting application lacks the required data, it will be ignored.


# CCAF protocol ratings (For projects)

* 10 | 9.5 - Assets with this rate are considered low-risk, high-return assets.
* 9.5 | 8.5 - Assets with this rate are considered low-risk, mid-return assets.
* 8.5 | 7.5 - Assets with this rate are considered low-risk, low-return assets.
* 7.5 | 6.5 - Assets with this rate are considered high-risk, high-return assets.
* 6.5 | 5 - Assets with this rate are considered high-risk, mid-return assets.
* 0 - Trusted stable assets.

All projects listed on the CCL are being rated on a scale of 10, where 10 is the highest investment opportunity. And 5 is a high risk investment.&#x20;

Please note that projects that get a CCL degree below 5 are not listed on the CCL. And assets with a CCL rate of 0 are considered trusted, stable assets.&#x20;

[Read ](/v2-documentation/ecosystem/lotus-finance/roots-previously-ccl/projects-verification/grading-system)to understand how the projects are being rated.


# Pyrabit Labs

The technologicial arm the provides us with the necessary technologies&#x20;


# SESHAT CHAIN (The ORACLE)

Lotus Ecosystem

Seshat is a purpose-built blockchain engineered for fintech applications. It operates through parallel layers to support specialized environments, including a dedicated government layer for select government decentralized applications. Seshat is designed to enable new use cases for fintechs and public-sector entities seeking a native chain that prioritizes privacy, security, and decentralization.\
\
Seshat technology will be announced in Phase two whitepapers.


# LTS TOKEN

The LTS token is the main fuel of the Lotus ecosystem.

Token has two main phases to go through.

### Phase one: the hyperdeflation (LTS token)

In the current phase of the BNB chain, the main target of that phase is to decrease LTS token total supply through taxes, LTS services, and buybacks before launching the LTS chain.

The total supply of LTS tokens at the end of phase one will be the total supply of Lotus coins on the LTS chain.

### Phase two: Lotus Coin

* Native LTS chain coin.
* No taxes.


# Phase One


# Token Metrics

* Total supply: 1,000,000,000 (1 Billion LTS).

* Series A funding: 125,000,000 (125 Million LTS).

* Seed sale: 25,000,000 (25 Million LTS).

* Liquidity: 120,000,000 (120 Million LTS).

Total Vested tokens in Q1, P1: 270,000,000 LTS (27% Of total supply).

* Series B funding: 120,000,000 (120 Million LTS).
* Staking rewards: 450,000,000 (450 Million LTS).
* Series C funding: 120,000,000 (120 Million LTS).
* Team allocation: 30,000,000 (30 Million LTS).
* Company reserve: 30,000,000 (30 Million LTS).


# Utility

* LTS CCL application fees
* HydraPad Fees
* CCAFP Checkers

More services will be announced in second phase roadmap.


# Burn mechanism

### Tax (implemented on transactions)

* 11% burn tax.

### Antibot mechanism&#x20;

Antibot taxes are additional taxes implemented on the transaction in the case of holding LTS for less than 7 hours.

* 3% additional burn tax.

Note that taxes are not fixed and will be decreased gradually.


# Lotus Coin


# Coin Metrics

Lotus Coin total supply will be determined before the LTS Chain launches according to final total supply of LTS Tokens left.


# Utility

* LTS Finance services
* LTS Chain services
* LTS CCL services

More will be announced in phase two road map.


# Important


# Lotus Cards Policy

25 June, 2026

This policy applies to Polycard, Neufero X and any card product issued, distributed, or made available under the Lotus Cards program.

### 1. Card Program

Lotus Cards are provided by Lotus Information Technologies in cooperation with licensed issuing banks, regulated financial institutions, card networks, payment processors, and approved program partners.

Lotus Information Technologies is responsible for the customer-facing platform, account experience, support, and program operations where applicable. The issuance, processing, custody, settlement, and regulated financial services connected to the card may be performed by licensed or authorized third-party partners.

The card is not a bank deposit account unless expressly stated by the relevant issuer. Card availability, supported countries, currencies, limits, and features may vary depending on the issuer, regulatory requirements, compliance checks, and network rules.

### 2. Protection of Customer Funds

#### Non-Custodial Wallet Arrangements

Where a card product is linked to or funded through a non-custodial wallet, the underlying funds or digital assets are held exclusively by the customer in a self-custodied wallet. Lotus Information Technologies does not hold, control, access, or take custody of such funds at any time.

The customer is solely responsible for the custody, security, and management of their non-custodial wallet, including the safekeeping of private keys, seed phrases, and any associated access credentials. Loss of access to a non-custodial wallet — including loss of private keys or seed phrases — is irreversible. Lotus Information Technologies cannot recover, restore, or provide access to funds held in a non-custodial wallet under any circumstances.

By using a card product linked to a non-custodial wallet, the customer acknowledges and accepts that Lotus Information Technologies assumes no liability, responsibility, or obligation in respect of any funds, assets, or value held in or lost from such wallet, except to the extent that any loss is directly caused by a verified technical failure on the part of Lotus Information Technologies' own systems.

#### Safeguarding

Where required by applicable law or regulation, customer funds held in connection with Lotus Cards are safeguarded in accordance with the requirements of the relevant issuer and regulatory framework. This may include segregation of customer funds from the operational funds of Lotus Information Technologies or its partners.

**UK customers:** Where the card is issued or operated under a UK-regulated Electronic Money Institution (EMI) or Payment Institution (PI) licence, customer funds may be protected in accordance with the FCA's safeguarding rules under the Electronic Money Regulations 2011 or the Payment Services Regulations 2017. Safeguarded funds are not covered by the Financial Services Compensation Scheme (FSCS) unless expressly stated by the relevant issuer.

**US customers:** Where the card is issued by a US-licensed issuing bank, funds may be eligible for FDIC insurance up to applicable limits. Please refer to the relevant issuer's disclosures for confirmation of FDIC eligibility.

The specific safeguarding arrangements applicable to your card will be confirmed in the issuer's terms and conditions provided at account opening.

### 3. Customer Eligibility

Customers must provide accurate, complete, and up-to-date information. Lotus Information Technologies and its partners may require identity verification, business verification, source of funds checks, sanctions screening, fraud screening, or enhanced due diligence before activating, maintaining, or restoring card access.

We may refuse, delay, suspend, or cancel card services where verification is incomplete, inaccurate, expired, inconsistent, or where required by law, regulation, issuer policy, network rules, or our internal risk controls.

### 4. Compliance, AML, CTF, and Sanctions

Lotus Information Technologies operates risk and compliance controls designed to prevent fraud, money laundering, terrorist financing, sanctions evasion, misuse of financial services, and other prohibited activity.

We may monitor card activity, deposits, top-ups, withdrawals, refunds, merchant activity, customer behavior, IP/location signals, blockchain transactions, and other relevant information for compliance and security purposes.

We apply AML, CTF, fraud, and sanctions controls in line with applicable laws and partner requirements, including relevant U.S., U.K., European, and international compliance frameworks where applicable.

Customers must not use the card for illegal activity, sanctions evasion, money laundering, fraud, gambling where prohibited, unauthorized resale, high-risk activity, circumvention of limits, abuse of promotions, suspicious transaction routing, or any activity that violates applicable law, card network rules, issuer policy, or Lotus policies.

### 5. Right to Suspend, Freeze, or Close a Card

Lotus Information Technologies, the issuer, or any authorized program partner may suspend, freeze, restrict, or close a card at any time if:

* suspicious, fraudulent, abusive, or manipulative activity is detected;
* the customer breaches this policy or any applicable terms;
* required verification is not completed;
* activity appears inconsistent with the customer profile;
* funds, deposits, or transactions require review;
* the card is used in a prohibited country, sector, merchant category, or activity;
* required by law, regulation, court order, regulator request, issuer policy, partner instruction, or card network rules;
* we reasonably believe action is needed to protect customers, Lotus, the issuer, partners, or the financial system.

Where legally permitted, we may notify the customer of the restriction and request additional information. In some cases, we may be legally restricted from disclosing the reason for the action.

### 6. Customer Requested Closure

A customer may request closure of their card at any time through the available support or account channels.

After a closure request, Lotus Information Technologies or its partners may disable new card activity and begin final settlement, subject to pending transactions, chargebacks, refunds, compliance review, network settlement timelines, and any legal or regulatory restrictions.

Where no hold, dispute, investigation, compliance restriction, or legal limitation applies, Lotus Information Technologies will use reasonable efforts to return the available card balance or complete final settlement within a maximum of 25 business days.

If funds are subject to investigation, dispute, chargeback, sanctions review, legal hold, regulatory request, or issuer restriction, settlement may be delayed until the matter is resolved.

### 7. Balance, Refunds, and Settlement

Available card balance may differ from displayed balance due to pending authorizations, reversals, refunds, FX adjustments, network settlement, fees charged by third parties, or compliance holds.

Refunds and settlements will be processed only to an approved destination, account, wallet, or payment method that satisfies our compliance and ownership checks.

Lotus Information Technologies may deduct or withhold amounts required to cover pending transactions, reversals, disputes, chargebacks, provider costs, network obligations, legal obligations, or confirmed losses caused by misuse or fraud.

### 8. Customer Responsibilities

Customers are responsible for keeping account credentials, card details, email access, devices, and authentication methods secure.

Customers must immediately notify support if they suspect unauthorized access, compromised credentials, incorrect card activity, or unauthorized transactions.

Customers must not share card data, authentication codes, one-time passwords, 3DS codes, or account access with any unauthorized person.

#### Card Data Security

The customer is solely responsible for the secure storage and handling of their card number, CVV, expiry date, PIN, and any other card credentials. Lotus Information Technologies shall not be liable for any loss, unauthorized transaction, or misuse arising from the customer's failure to keep card data secure, including but not limited to loss resulting from phishing, social engineering, device compromise, or voluntary disclosure to a third party.

Lotus Information Technologies is responsible only for the security of card data held within its own systems and infrastructure. In the event of a confirmed security breach originating from Lotus Information Technologies' own systems, customers will be notified in accordance with applicable data protection law and the relevant issuer's breach response procedures.

#### PCI DSS Compliance

The display, transmission, and storage of card data within the Lotus Cards platform is handled in accordance with the Payment Card Industry Data Security Standard (PCI DSS). Lotus Information Technologies maintains PCI DSS-compliant processes for the presentation of card credentials, including card number masking, secure display environments, and access controls designed to prevent unauthorized exposure of sensitive card data. Customers should be aware that PCI DSS compliance applies to Lotus Information Technologies' own systems and does not extend to the customer's own devices, networks, or third-party applications through which card data may be accessed or transmitted.

#### Card Closure

A customer may request closure of their card at any time by contacting support through the available account channels or by emailing <compliance@ltsfinance.com>. Closure requests will be processed subject to the terms set out in Section 6 (Customer Requested Closure) of this policy.

### 9. Changes to Card Services

Lotus Information Technologies may update card features, limits, availability, supported countries, settlement methods, compliance requirements, or this policy from time to time.

Material changes will be communicated where required. Continued use of the card after an update means the customer accepts the updated policy.

### 10. Complaints

If you are dissatisfied with any aspect of your card service, you have the right to make a formal complaint.

**How to complain:** Complaints may be submitted by contacting Lotus Information Technologies by email at <compliance@ltsfinance.com> or through the support channels available in your account.

**Our process:** We will acknowledge your complaint promptly and aim to provide a full response within 15 business days. In exceptional circumstances, we will notify you if more time is required, with a final response issued no later than 35 business days from receipt of your complaint.

**UK customers:** If you are not satisfied with our final response, or if you have not received a response within 8 weeks, you may refer your complaint to the Financial Ombudsman Service (FOS) free of charge. Details are available at [www.financial-ombudsman.org.uk](http://www.financial-ombudsman.org.uk/).

**US customers:** If you are not satisfied with our response, you may contact the Consumer Financial Protection Bureau (CFPB) at [www.consumerfinance.gov](http://www.consumerfinance.gov/) or call 1-855-411-2372.

Complaints relating to regulated payment services in the UK are handled in accordance with the FCA's Dispute Resolution (DISP) rules.

### 11. Final Authority

Card services are subject to issuer approval, partner approval, applicable law, card network rules, compliance requirements, and operational availability. If there is any conflict between this policy and mandatory legal, issuer, partner, or network requirements, those requirements will prevail.

#### Governing Law and Jurisdiction

This policy is governed by and construed in accordance with the laws of England and Wales. Any dispute arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the courts of England and Wales, unless mandatory local law in the customer's country of residence requires otherwise.

Where Lotus Cards services are provided to customers in the United States, applicable U.S. federal and state laws — including the Electronic Fund Transfer Act (EFTA), Regulation E, and any applicable state money transmission laws — shall apply to the extent required by law, and shall prevail over this policy to the extent of any conflict.


# Contact us

* Support: <support@ltsfinance.com>
* Legal & Compliance: <compliance@ltsfinance.com>


# Social links

* LinkedIn:[ ](https://www.linkedin.com/company/ltsnet)<https://www.linkedin.com/company/ltsnet>
* Instagram: <https://www.instagram.com/ltsnet>
* Twitter:[ ](https://www.twitter.com/ltsnet)<https://www.twitter.com/ltsnet>
* Facebook: <https://www.facebook.com/ltsfi>
* WhatsApp: <https://wa.me/+201068790593>
* Telegram:[ ](https://www.telegram.me/ltsnet)<https://www.telegram.me/ltsnet>


# Privacy Policy

Herein is provided the privacy policy of Lotus Network (owner and operator of lotusnetwork.net, ltsfinance.com, ltsccl.com) This Privacy Policy describes how Lotus Network will manage end user’s personal information which we collect as a result of your use of Lotus Network, your use of our websites located at <https://lotusnetwork.net/> and any pages or websites under the 'Lotus Network' brand including any tablet or mobile phone applications that are owned and/or operated by us or whenever we otherwise deal with you. Lotus Network is committed to ensuring that the personal information we collect about you is protected and is used, stored and disclosed in accordance with the Privacy Act and this Privacy Policy.<br>

### **Website Use**

In using the website, you agree to be bound by the terms of this Privacy Policy. Lotus Network may review the Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its discretion by posting such changes on the website. Changes will be effective immediately when posted on the website. The end users’ continued use of the website following posting will constitute your acceptance of those changes. This Privacy Policy will not apply to websites which are linked to the website and over which Lotusnetwork.net has no control.

### **Personal Information**

The kinds of Personal Information that Lotus Network may collect from you is: Name Email address Personally submitted preferences Location data IP address

### &#x20;**Collection Purposes**

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Lotus Network will collect your Personal Information only by lawful and fair means and not in an intrusive way to operate its Service, and to provide you with the following information: If you wish to subscribe to Lotus Network weekly newsletter or other marketing communications. To update you on technical progress of Lotus Network. To provide services to you as a User. To identify you as a User for security purposes and to comply with our legal obligations. To upgrade and enhance your experience within the website or over the telephone, or to tailor or develop information, services or products to suit your needs which may include market research and conducting promotions. To tell you about our products or services that we think may be of interest to you by communicating with you via email, SMS or telephone. To create aggregate data about Users through demographic profiling, statistical analysis of the database to provide to potential and existing Lotus Network holders, and to allow for more efficient operation of Lotus Network business. To comply with Lotus Network legal and statutory obligations. For taking appropriate action if Lotus Network has reason to suspect that unlawful activity or misconduct of a serious nature has been, is being or may be engaged in that relates to our functions and activities. To establish, exercise or defend any legal claims. Manage job applications. You may choose to deal with us on an anonymous basis or to use a pseudonym unless it is not practicable for us to deal with individuals who we cannot identify or we are required by law to only deal with identified individuals. Also, if you do not provide Lotus Network with the Personal Information we request, we may be unable to process your request to become a User, provide you with our services or respond to your enquiry or complaint. Examples of Personal Information that may be collected by Lotus Network include your name, email address, telephone numbers, your date of birth, other verification information such as your Service usage activities. By becoming a User or otherwise choosing to provide Lotus Network with Personal Information you consent to Lotus Network collecting, using and disclosing your Personal Information for the above purposes.

### &#x20;**Direct Marketing and Opting Out**

Occasionally we may use your Personal Information to inform you about Lotus Network products or services or about promotional activities which Lotus Network believes may be of interest or of benefit to you. We may do this via email, SMS, telephone or mail. If you no longer wish to receive marketing or promotional material from Lotus Network at all or in any particular form, you may contact us at any time by email to <support@lotusnetwork.net> with your request with which we will comply as soon as is practical. From time to time we may contact you in relation to the management and administration of your Lotus Network account. These communications can be via any of the modes of contact recorded when registering as a User. Such communication does not affect your opt-in or opt-out status for direct marketing communications.

### **Management of your Personal Information**

Lotus Network will take all reasonable steps to ensure that the Personal Information which it collects, uses or discloses is correct and is stored in a secure environment which is accessed only by authorised persons. Lotus Network will destroy or permanently de-identify the Personal Information we hold when it is no longer required for any purpose permitted under the APPs including our legal or operational obligations.

### &#x20;**Security of Personal Information**

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You acknowledge that no data transmission over the Internet is totally secure. Accordingly, Lotus Network does not warrant the security of any information which you transmit to it. Any information which you transmit to Lotus Network is transmitted at your own risk. However, once Lotus Network receives your transmission, Lotus Network will take reasonable steps to protect your Personal Information from misuse, loss and unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer (SSL) technology. Lotus Network employees, agents and contractors are required to maintain the confidentiality of Users’ Personal Information and trading behaviour. Information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms) becomes public information. Lotus Network cannot guarantee the security of this type of disclosed information. We take seriously the responsibility to exclude children from access to our services. We will not accept their information for the purposes of accessing or using the Service. It is however, ultimately the responsibility of parents or guardians to monitor their children’s Internet activities including where appropriate by using Internet screening software. Remember to always log out of your account when you have completed your time on the website. This is particularly important if you share a computer with another person. You are responsible for the security of and access to your own computer, mobile device or any other handset used to access the website. Ultimately, you are solely responsible for maintaining the secrecy of your username, password and any account information. Please be careful whenever using the Internet and our website.

### &#x20;**Access to Personal Information**

You may access the Personal Information collected by Lotus Network by contacting us at <support@lotusnetwork.net>. We will give you access to your Personal Information in the manner requested if that is possible and within a reasonable period. If we refuse your request or cannot give you access in the manner you have requested, we will do what we can to meet your requirements by other means. We may not be required to give you access to your Personal Information in certain circumstances which are set out in the APPs including where it may have an unreasonable impact on other individual's privacy. If we refuse access for such reasons, we will advise you in writing of the refusal and our reasons and the complaint mechanisms available to you.

### **Use of Website**

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By using this website, you agree to Lotus Network collecting and processing your Personal Information on the basis explained in this Privacy Policy. Contact Details If you have any queries, requests for access or correction or complaints relating to the handling of your personal information, please contact us by email. Email: <support@lotusnetwork.net>

### **Updates to this Privacy Policy**

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Lotus Network may review, change and update this Privacy Policy to reflect our current practices and obligations. We will publish our current Privacy Policy on our website at [www.lotusnetwork.net](https://docs.lotusnetwork.net/v2-documentation/important/www.lotusnetwotk.net) and the changes will take effect at the time of publishing. You should review this privacy policy regularly and remain familiar with its terms.

### CCPA Privacy Rights (Do Not Sell My Personal Information)<br>

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Under the CCPA, among other rights, California consumers have the right to: Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers. Request that a business delete any personal data about the consumer that a business has collected. Request that a business that sells a consumer's personal data, not sell the consumer's personal data. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

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# Handling and storing data

### Breach sanction

Please note that the CCL is not selling, using, or exposing your data by any means. Data is being revealed in one and only one case: a severe law breach, which includes one of the following:

* Money laundering operation provided by reasonable, undeniable evidence by an official judging authority.
* Fraud related activities such as receiving and sending of a stolen or hacked assets proven by reasonable, undeniable evidence and a bad faith

All wallets or contracts that are involved with the cases mentioned above are going to be listed in the blacklisted section of the CCL as well as the CCL smart contract on the chain. revealing the identity of the breach causer and all the necessary data to the involved judging authority.

### How your data is being stored and protected by the CCL

* Customers data on the CCL system are not stored on blockchain.
* Customers data on the CCL system are not stored in any third party service.
* Customer data on the CCL system is not stored in any online accessible service.
* Customer data on the CCL system is encrypted.

### What are the obligations of the CCL towards your data

* Not sharing the data you provided us with a third party app.
* Not revealing the data you provided us with any public authority that didn't provide sufficient, undeniable evidence to reveal it.
* Not revealing the data you provided us to any private entity that didn't provide sufficient, undeniable evidence to reveal it.
* Not using the data you provided us a commercial use.
* If your data got blacklisted The CCL system is obliged to inform you by email and will attach the evidence on which the decision was made before revealing your data.

#### *By applying for verification on the CCL system, you have read and approved the statement above*.


# Terms of Service

### **Acceptance of the Website Terms and Conditions of Use**

These website terms and conditions should be read by you (the "User," "Users, " "you") in its entirety prior to your use of Lotus Network service or products. These website terms and conditions of use for Lotus Network, constitute a legal agreement and are entered into by and between you and Lotus Network ("Company," "we," "us," "our"). The following terms and conditions, together with any documents and/or additional terms they expressly incorporate by reference (collectively, these "Terms and Conditions"), govern your access to and use, including any content, functionality, and services offered on or through Lotus Network (the "Website").

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BY USING THE WEBSITE, YOU ACCEPT AND AGREE TO BE BOUND AND COMPLY WITH THESE TERMS AND CONDITIONS AND [OUR PRIVACY POLICY](/v2-documentation/important/privacy-policy), INCORPORATED HEREIN BY REFERENCE. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS OR THE PRIVACY POLICY, YOU MUST NOT ACCESS OR USE THE WEBSITE.

### &#x20;**Modifications to the Terms and Conditions and to the Website**

We reserve the right in our sole discretion to revise and update these Terms and Conditions from time to time. Any and all such modifications are effective immediately upon posting and apply to all access to and continued use of the Website. You agree to periodically review the Terms and Conditions in order to be aware of any such modifications and your continued use shall be your acceptance of these. The information and material on this Website, and the Website, may be changed, withdrawn, or terminated at any time in our sole discretion without notice. We will not be liable if, for any reason, all or any part of the Website is restricted to users or unavailable at any time or for any period.

### &#x20;**Intellectual Property Rights and Ownership**

You understand and agree that the Website and its entire contents, features, and functionality, including, but not limited to, all information, software, code, technology, text, displays, graphics, photographs, video, audio, design, presentation, selection, and arrangement, are owned by the Company, its licensors, or other providers of such material and are protected in all forms by intellectual property laws including without limitation, copyright, trademark, patent, trade secret, and any other proprietary rights. The Company name, the LIST COMPANY TRADEMARKS, the Company logo, and all related names, logos, product and service names, designs, images, and slogans are trademarks of the Company or its affiliates or licensors. You must not use such marks without the prior written permission of the Company. Other names, logos, product and service names, designs, images, and slogans mentioned, or which appear on this Website are the trademarks of their respective owners. Use of any such property, except as expressly authorized, shall constitute an infringement or violation of the rights of the property owner and may be a violation of federal or other laws and could subject the infringer to legal action. You may only use the Website for your personal and non-commercial use. You shall not directly or indirectly reproduce, copy, compile for an internal database, distribute, modify, create derivative works of, publicly display, publicly perform, republish, reverse engineer, decompile, disassemble, modify, translate, download, store, or transmit any of the material on our Website, in any form or medium whatsoever except:

* (a) your computer and browser may temporarily store or cache copies of materials being accessed and viewed;
* (b) a reasonable number of copies for personal use only may be printed keeping any proprietary notices thereon, which may only be used for non-commercial and lawful personal use and not for further reproduction, publication, or distribution of any kind on any medium whatsoever;
* (c) one single user copy may be downloaded with any proprietary notices intact, for your own personal, non-commercial use, conditional on your agreement to be bound by our end user licence agreement for such downloads

Users are not permitted to modify copies of any materials from this Website nor delete or alter any copyright, trademark, or other proprietary rights notices from copies of materials from this site. You must not access or use for any commercial purposes any part of the Website or any services or materials available through the Website. If you print off, copy or download any part of our Website in breach of these Terms and Conditions, your right to use the Website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made. You have no right, title, or interest in or to the Website or to any content on the Website, and all rights not expressly granted are reserved by the Company. Any use of the Website not expressly permitted by these Terms and Conditions is a breach of these Terms and Conditions and may infringe or violate copyright, trademark, and other intellectual property or other proprietary laws. You agree that you will be solely liable for any damage, costs or expenses arising out of or in connection with such breach, infringement or violation of these Terms and Conditions. You shall notify the Company immediately upon becoming aware of the commission by any person of any such breach, infringement or violation and shall provide the Company with reasonable assistance with any investigations it conducts in light of the information provided by you in this respect.

### &#x20;**Conditions of Use**

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As a condition of your access and use, you agree that you may use the Website only for lawful purposes and in accordance with these Terms and Conditions. You warrant and agree that your use of the Website shall not: In any manner violate any applicable federal, provincial, local, or international law or regulation including, without limitation, any laws regarding the export of data or software, patent, trademark, trade secret, copyright, or other intellectual property, legal rights (including the rights of publicity and privacy of others) or contain any material that could give rise to any civil or criminal liability under applicable laws or regulations or that otherwise may be in conflict with these Terms and Conditions and our Privacy Policy found at [Our Privacy Policy](/v2-documentation/important/privacy-policy). In any manner violate the terms of use of any third-party website that is linked to the Website, including but not limited to, any third-party social media website. Include or contain any material that is exploitive, obscene, harmful, threatening, abusive, harassing, hateful, defamatory, sexually explicit or pornographic, violent, inflammatory, or discriminatory based on race, sex, religion, nationality, disability, sexual orientation, or age or other such legally prohibited ground or be otherwise objectionable, such determination to be made in Company's sole discretion. Involve stalking, attempting to exploit or harm any individual (including minors) in any way by exposing them to inappropriate content or otherwise or ask for personal information as prohibited under applicable laws, regulations, or code. Involve, provide, or contribute any false, inaccurate, or misleading information. Impersonate or attempt to impersonate the Company, a Company employee, another user, or any other person or entity (including, without limitation, by using email addresses, or screen names associated with any of the foregoing). Transmit, or procure the sending of, any advertisements or promotions without our prior written consent, sales, or encourage any other commercial activities, including, without limitation, any "spam", "junk mail", "chain letter", contests, sweepstakes and other sales promotions, barter, or advertising or any other similar solicitation. Encourage any other conduct that restricts or inhibits anyone's use or enjoyment of the Website, or which, as determined by us, may harm the Company or users of the Website or expose them to liability. Cause annoyance, inconvenience, or needless anxiety or be likely to upset, embarrass, or alarm any other person. Promote any illegal activity, or advocate, promote, or assist any unlawful act. Give the impression that they originate from or are endorsed by us or any other person or entity, if this is not the case.

### &#x20;**Prohibited Uses**

The Website is intended solely for the User’s personal use. The User is only allowed to use the Website for personal use, and may not create multiple accounts, including for the purpose of collusion and/or abuse of service. The Website is provided as is, and any exploitation of the Website or errors in program logic and/or code (bugs) constitutes a prohibited use and a material breach of these Terms and Conditions. Any funds the user may misappropriate in this manner pursuant to this clause shall be considered void and the immediate property of the Company, without limit. Persons located in or residents of the United States, North Korea, Iran, Venezuela or any other jurisdiction in which it is prohibited from using the Website (the "Prohibited Jurisdictions") are not permitted to make use of the Website. For the avoidance of doubt, the foregoing restrictions on the Website from Prohibited Jurisdictions applies equally to residents and citizens of other nations while located in a Prohibited Jurisdiction. Any attempt to circumvent the restrictions on usage by any persons located in a Prohibited Jurisdiction is a breach of this Agreement. An attempt at circumvention includes, but is not limited to, manipulating the information used by the Company to identify your location and providing the Company with false or misleading information regarding your location or place of residence. Any and all monies (including cryptocurrencies) of a person located in a Prohibited Jurisdiction on the Website are VOID, and can be confiscated or may be returned to the person at the Company’s sole discretion.

### &#x20;**Privacy**

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By using this Website you are consenting to the use of cookies which allow a server to recall previous requests or registration and/or IP addresses to analyze website use patterns. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies. If you do, however, some areas of the Website may not function adequately. For more information on this automated information gathering practices, see [Our Privacy Policy](/v2-documentation/important/privacy-policy)

### &#x20;**Third-Party Websites**

For your convenience, this Website may provide links or pointers to third-party sites. We make no representations about any other websites that may be accessed from this Website. If you choose to access any such sites, you do so at your own risk. We have no control over the contents of any such third-party sites and accept no responsibility for such sites or for any loss or damage that may arise from your use of them. You are subject to any terms and conditions of such third-party sites. Such links to third-party sites from the Website may include links to certain social media features that enable you to link or transmit on your own or using certain third-party websites, certain content from this Website. You may only use these features when they are provided by us and solely with respect to the content identified. You may link to our homepage, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval, or endorsement on our part where none exists. Our Website must not be framed on any other site, nor may you create a link to any part of our Website other than the homepage. We reserve the right to withdraw linking permission without notice. The website in which you are linking must comply in all respects with the Conditions of Use. You agree to cooperate with us in causing any unauthorized framing or linking to immediately stop.

### **User Representations and Warranties**

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Prior to your use of the Website and on an ongoing basis you represent, warrant, covenant and agree that: Cryptocurrency values can fluctuate greatly in value depending on market conditions. You warrant that you are aware of the volatile nature of cryptocurrencies and the risk of losing cryptocurrency and other funds of value when using this Website and hold the Company harmless for any loss or damages arising from such volatility. Your use of the Website is at your sole option, discretion and risk. You are solely responsible for any applicable taxes which may be payable on cryptocurrency traded or transacted by you through your using the Website. The telecommunications networks, blockchain networks (such as Lotus Network ) and Internet access services required for you to access and use the Website are entirely beyond the control of the Company and the Company shall have no liability whatsoever for any outages, slowness, capacity constraints or other deficiencies affecting the same. You are (i) aged 18 or over, (ii) you are of the age of majority in your jurisdiction, (iii) you are accessing the Website from a jurisdiction in which it is legal to do so, (iv) you are not a Politically Exposed Person ("PEP") nor are you on any U.S. or EU Sanctions lists or terrorism finance watchlists, and (v) that you will inform the Company immediately if you enter onto one of these lists or change your residence to a jurisdiction in which accessing the Website is illegal, such as a Prohibited Jurisdiction. The Company expressly prohibits and rejects the use of the Website for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various jurisdictions’ laws, regulations and norms. To that end, the Website is not offered to individuals or entities on any Politically Exposed Persons (PEP) lists, or subject to any United States, European Union, or other global sanctions or watch lists. By using the Website, you represent and warrant that you are not on any such lists. If you access this Website, you do so at your own risk and you are responsible for compliance with local laws of your jurisdiction. Lotus Network does not have the ability to verify the legality of the Website in every jurisdiction, therefore it is entirely up to the User to determine whether or not their use of the Website is lawful. You are prohibited from using the Website if you are accessing the Website from a Prohibited Jurisdiction.<br>

### **Disclaimer of Warranties**

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YOU UNDERSTAND AND AGREE THAT YOUR USE OF THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT ANY WARRANTIES OR CONDITIONS OF ANY KIND, EITHER EXPRESS OR IMPLIED INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. THE FOREGOING DOES NOT AFFECT ANY WARRANTIES THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW. NEITHER THE COMPANY NOR ITS PARENT, SUBSIDIARIES, AFFILIATES, OR THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS, OR SUCCESSORS MAKE ANY WARRANTY, REPRESENTATION, OR ENDORSEMENT WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, SUITABILITY, ACCURACY, CURRENCY, OR AVAILABILITY OF THE WEBSITE OR ITS CONTENTS. WITHOUT LIMITING THE FOREGOING, NEITHER THE COMPANY NOR ITS PARENT, SUBSIDIARIES, AFFILIATES OR THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS, OR SUCCESSORS REPRESENT OR WARRANT THAT THE WEBSITE, ITS CONTENT, OR ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE, OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED. WE CANNOT AND DO NOT GUARANTEE OR WARRANT THAT FILES OR DATA AVAILABLE FOR DOWNLOADING FROM THE INTERNET OR THE WEBSITE WILL BE FREE OF VIRUSES OR OTHER DESTRUCTIVE CODE. YOU ARE SOLELY AND ENTIRELY RESPONSIBLE FOR YOUR USE OF THE WEBSITE AND YOUR COMPUTER, INTERNET, AND DATA SECURITY. TO THE FULLEST EXTENT PROVIDED BY LAW, WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY DENIAL-OF-SERVICE ATTACK, DISTRIBUTED DENIAL-OF-SERVICE ATTACK, OVERLOADING, FLOODING, MAILBOMBING, OR CRASHING, VIRUSES, TROJAN HORSES, WORMS, LOGIC BOMBS, OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA, OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

### &#x20;**Limitation on Liability**

EXCEPT WHERE SUCH EXCLUSIONS ARE PROHIBITED BY LAW, UNDER NO CIRCUMSTANCE WILL THE COMPANY NOR ITS PARENT, SUBSIDIARIES, AFFILIATES OR THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS, OR SUCCESSORS BE LIABLE FOR NEGLIGENCE, GROSS NEGLIGENCE, NEGLIGENT MISREPRESENTATION, FUNDAMENTAL BREACH, DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING, BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT, BREACH OF PRIVACY, OR OTHERWISE, EVEN IF THE PARTY WAS ALLEGEDLY ADVISED OR HAD REASON TO KNOW, ARISING OUT OF OR IN CONNECTION WITH YOUR USE (OR MISUSE), OR INABILITY TO USE, OR RELIANCE ON, THE WEBSITE, ANY LINKED WEBSITES OR SUCH OTHER THIRD-PARTY WEBSITES, NOR ANY WEBSITE CONTENT, MATERIALS, POSTING, OR INFORMATION THEREON EVEN IF THE PARTY WAS ALLEGEDLY ADVISED OR HAD REASON TO KNOW. NOTHING IN THESE TERMS AND CONDITIONS SHALL EXCLUDE OR LIMIT THE COMPANY’S LIABILITY FOR DEATH OR PERSONAL INJURY RESULTING FROM ITS NEGLIGENCE.

### &#x20;**Force Majeure**

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You agree and understand that in no event shall the Company be liable for any delays, failure in performance or interruption of service which result directly or indirectly from any cause or condition, whether or not foreseeable, beyond the Company’s reasonable control, including, but not limited to, any act of God, nuclear or natural disaster, epidemic, action or inaction of civil or military authorities, act of war, terrorism, sabotage, civil disturbance, strike or other labor dispute, accident, state of emergency or interruption, loss, or malfunction of equipment or utility, communications, computer (hardware or software), Internet or network provider services.

### &#x20;**Indemnification**

To the maximum extent permitted by applicable law, you agree to defend, indemnify, and hold harmless the Company, its parent, subsidiaries, affiliates, and their respective directors, officers, employees, agents, service providers, contractors, licensors, suppliers, successors, and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to your breach of these Terms and Conditions, violation by you of any law or any third party rights, or your use of the Website, including, but not limited to, third-party sites, any use of the Website's content, services, and products other than as expressly authorized in these Terms and Conditions.

### **Governing Law and Choice of Forum**

The Website and these Terms and Conditions will be governed by and construed in accordance with the laws of the British Virgin Islands applicable therein, without giving effect to any choice or conflict of law provision, principle, or rule (whether of the laws of the British Virgin Islands or any other jurisdiction) and notwithstanding your domicile, residence, or physical location. Any action or proceeding arising out of or relating to this Website and under these Terms and Conditions will be instituted in the courts of the British Virgin Islands, and each party irrevocably submits to the exclusive jurisdiction of such courts in any such action or proceeding. You waive any and all objections to the exercise of jurisdiction over you by such courts and to the venue of such courts. Nothing in this clause shall limit the right of the Company to take proceedings against you in any other court of competent jurisdiction, nor shall the taking of proceedings in any one or more jurisdictions preclude the taking of proceedings in any other jurisdictions, whether concurrently or not, to the extent permitted by the law of such other jurisdiction.

### &#x20;**Waiver**

No failure to exercise, or delay in exercising, any right, remedy, power, or privilege arising from these Terms and Conditions operates, or may be construed, as a waiver thereof by the Company. No single or partial exercise of any right, remedy, power, or privilege hereunder precludes any other or further exercise thereof or the exercise of any other right, remedy, power, or privilege.

### &#x20;**Severability**

If any term or provision of these Terms and Conditions is invalid, illegal, or unenforceable in any jurisdiction, such invalidity, illegality, or unenforceability shall not affect any other term or provision of these Terms and Conditions or invalidate or render unenforceable such term or provision in any other jurisdiction.

### **Assignment**

These Terms and Conditions, or your rights and obligations hereunder, may not be transferred by you, but may be assigned by the Company without restriction. Any attempted transfer or assignment by you in violation hereof shall be null and void. These Terms and Conditions shall be binding and inure to the benefit of the parties hereto, our successors, and permitted assigns.

### &#x20;**Miscellaneous**

Nothing in these Terms and Conditions shall create or be deemed to create a partnership, agency, trust arrangement, fiduciary relationship or joint venture between you and the Company. Nothing in these Terms and Conditions shall create or confer any rights or other benefits in favour of any third parties not party to these Terms and Conditions.

### &#x20;**Entire Agreement**

The Terms and Conditions and our Privacy Policy constitute the sole and entire agreement between you and DxSale regarding the Website and supersedes all prior and contemporaneous understandings, agreements, representations and warranties, both written and oral, regarding such subject matter.

### &#x20;**Reporting and Contact**

All other feedback, comments, requests for technical support, and other communications relating to the Website should be directed to <support@lotusnetwork.net>.

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# ANTI-MONEY LAUNDERING (AML) POLICY

**LOTUS INFORMATION TECHNOLOGIES LTD**\
*Last Updated: Monday, April 29, 2025*

***

### 1. Purpose

This AML Policy outlines the commitment of **LOTUS INFORMATION TECHNOLOGIES LTD** ("the Company") to detect, prevent, and report money laundering and terrorism financing activities in accordance with the **UK Money Laundering Regulations 2017**, the **Proceeds of Crime Act 2002**, and guidance provided by the **Financial Conduct Authority (FCA)**.

***

### 2. Scope

This policy applies to all products, services, customers, employees, and business operations of the Company, including the operation of our fintech platform and cryptocurrency wallet services.

***

### 3. AML Compliance Officer

We designate an **AML Compliance Officer (MLRO)** responsible for:

* Overseeing the Company’s AML compliance program
* Receiving and investigating internal suspicious activity reports (SARs)
* Filing SARs with the National Crime Agency (NCA)
* Training staff and reviewing AML policies regularly

***

### 4. Customer Due Diligence (CDD)

We implement risk-based CDD for all customers:

* **Standard CDD** for regular users
* **Enhanced Due Diligence (EDD)** for high-risk users, including:
  * Politically Exposed Persons (PEPs)
  * Users from high-risk jurisdictions
  * Transactions above defined thresholds

**CDD Process includes:**

* Identity verification (name, address, DOB)
* Document collection (passport, utility bills, etc.)
* Liveness checks and biometric verification
* Ongoing monitoring

***

### 5. Know Your Customer (KYC)

We collect and verify user data via reliable, independent sources. Our KYC checks include:

* Name matching against global sanctions lists (e.g., OFAC, UN)
* Proof of address
* Source of funds and wealth when required

***

### 6. Ongoing Monitoring

We monitor customer transactions for:

* Large or unusual transfers
* Rapid movement of funds across wallets
* Use of mixing services or privacy coins (e.g., Monero)
* Layering or other suspicious behaviors

Flagged transactions are reviewed manually and may trigger a SAR.

***

### 7. Suspicious Activity Reporting (SAR)

If suspicious activity is identified, the AML Officer will:

1. Document the transaction details
2. Evaluate the suspicion internally
3. Submit a SAR to the NCA (UK) using the SAR Online system

**Important:** Staff are prohibited from *"tipping off"* the customer under UK law.

***

### 8. Record Keeping

We retain the following records for **at least 5 years**:

* KYC documents and verifications
* Transaction logs
* SARs and internal communications
* AML training records

***

### 9. Staff Training

All employees undergo mandatory AML training:

* At onboarding
* Annually
* Whenever regulations or internal procedures change

***

### 10. Risk Assessment

We maintain a documented, risk-based approach that considers:

* Customer type
* Transaction type and size
* Delivery channel (e.g., mobile app, web)
* Jurisdiction

Our risk assessment framework is reviewed and updated periodically.

***

### 11. Independent Audit

We commission periodic, independent audits of our AML program to ensure compliance with UK laws and internal standards.


# Whitepapers

v2 Whitepapers [HERE](https://cdn.ltsfinance.com/lotusWhitePapersV2.pdf)