1. Regulatory framework
Luminar Invest Capital DMCC operates under the United Arab Emirates Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, as amended, and applies the recommendations of the Financial Action Task Force (FATF).
2. Customer due diligence (CDD)
Before opening any account, Luminar Invest conducts mandatory identification and verification:
- Government-issued photo identification (passport or Emirates ID)
- Selfie liveness check matched against the identity document
- Proof of residential address less than 3 months old
- Declaration of source of funds and source of wealth
- Suitability and appropriateness questionnaire
3. Enhanced due diligence (EDD)
EDD is triggered for politically exposed persons (PEP), clients from FATF high-risk jurisdictions, complex legal structures, or transactions exceeding USD 100,000.
4. Sanctions screening
All clients and beneficial owners are screened against UN Security Council, UAE Local Terrorist List, OFAC, EU and HMT sanctions lists at onboarding and continuously thereafter.
5. Transaction monitoring
Luminar Invest monitors transactions on a risk-based approach. Suspicious activity is reported to the UAE Financial Intelligence Unit (FIU) through the goAML platform without notice to the client.
6. Record keeping
All KYC documents, transaction records and correspondence are retained for a minimum of five (5) years after the end of the business relationship.
7. Money Laundering Reporting Officer
The MLRO is responsible for the overall AML/CFT framework and is the sole point of contact with the FIU. The MLRO can be reached at contact@luminarinvest.com.
8. Training
All staff complete annual mandatory AML/CFT training and a refresher whenever the regulatory framework is updated.