Prohibited Business Activities

Updated on June 17, 2026.

High-risk and prohibited industries under Lumx's AML/CFT, sanctions, and partner-bank policies.

Every customer has to fully disclose their business activities to Lumx during onboarding and on an ongoing basis. We use that disclosure to run the right risk assessment, apply the right controls, and stay compliant with AML/CFT, sanctions, and regulatory requirements.

Not disclosing relevant activity can lead to onboarding rejection, account suspension, or termination.

High-risk business activities

Allowed with disclosure, risk assessment, and Enhanced Due Diligence.

Being in one of the categories below doesn't disqualify you — it triggers EDD and ongoing monitoring. You have to disclose these activities up front.

This list isn't exhaustive:

  • Money services, payment processing, or funds transmission (MSBs, PSPs, P2P platforms, prepaid or gift cards, ATM operators)

  • Licensed lending, foreign exchange, and securities brokerage

  • Virtual asset service providers (VASPs): crypto exchanges, OTC desks, wallet providers, custody or escrow, stablecoin issuers

  • Decentralized finance (DeFi), DAOs, foundations, gaming, metaverse, or other virtual asset ecosystems

  • Issuing, holding, safeguarding, or managing client funds, digital assets, stablecoins, or wallets

  • Trading, brokering, or dealing in high-value or trade-exposed goods — precious metals and stones, jewelry, oil and gas, mining, agriculture, construction, and real estate

  • Cash-intensive businesses — convenience stores, liquor retail, restaurants operating on cash, car washes

  • Licensed gambling, betting, or gaming operators

  • Crowdfunding platforms

  • Licensed investment advisors and asset managers

  • Businesses with complex or multi-layered ownership structures

  • Customers where a principal owner or controlling person is a politically exposed person (PEP)

High-risk customers may be asked for additional documents via Request for Information (RFI). Plan for verification windows beyond the standard SLA.

Prohibited business activities

Not supported under any circumstances. Lumx doesn't serve businesses engaged in the following activities, directly or indirectly, regardless of jurisdiction or licensing claims.

CategoryDescription
Adult content and sexually oriented servicesBusinesses offering or facilitating sexually explicit, obscene, or adult-oriented content or services.
Drugs, controlled substances, and unlicensed pharmaceuticalsSale, distribution, or facilitation of illegal or controlled substances, including cannabis and unlicensed pharmaceuticals.
Tobacco and tobacco-related productsManufacture, distribution, or sale of tobacco products and related services.
Weapons, ammunition, and explosivesTrading or dealing in weapons, firearms, ammunition, or weapon-related products.
Unlicensed gambling, betting, and games of chanceAny business involving unlicensed or prohibited games of chance, betting, or casinos. Licensed operators fall under high-risk.
Fraudulent and predatory financial modelsPonzi schemes, pyramid schemes, deceptive practices, and abusive or predatory lending.
Unlicensed money servicesMoney transmitters, payment processors, virtual asset providers, and remittance operators without the required licenses in their jurisdiction.
Shell banks and unsupervised banking structuresShell banks, offshore banks without physical presence, correspondent accounts for shell banks, payable-through accounts, and concentration accounts. See Nested Payments.
Unlicensed investment products and fundsNon-deposit investment products, trust and asset-management services, and trade finance operations without the required licenses.
Client trust and pass-through accountsIOLTA-style lawyer trust accounts, escrow accounts on behalf of unidentified beneficiaries, and any structure where Lumx-held funds belong to a non-onboarded party. See Nested Payments.
Hate, violence, terrorism, and discriminatory activityActivities promoting or enabling harm, hate, exploitation, or terrorism, including known terrorist organizations.
Sanctioned and illicit entitiesEntities or individuals on OFAC, EU, UN, UK, or other sanctions lists, or operating from jurisdictions under comprehensive embargoes. See Supported countries.
Identity fraud, anonymity misuse, and shell structuresAnonymous or fictitious accounts, bearer-share companies, or entities designed to obscure beneficial ownership.
Intellectual property infringement and counterfeit goodsEntities selling, distributing, or enabling IP-infringing or counterfeit products.
Data misuse and consumer privacy violationsBusinesses that compromise customer data or privacy.
Governmental, diplomatic, and political entitiesGovernment bodies, embassies, consulates, supranational organizations, and diplomatic entities.
Charities and NGOsNon-governmental organizations, charitable foundations, and non-profit entities.

Consequences of violation

If prohibited activity is found on a Lumx account:

  • The account is reviewed and may be suspended or terminated.

  • Funds may be frozen pending investigation.

  • Partners and authorities may be notified, in line with legal and contractual obligations.

Reporting violations

If you spot prohibited activity on the platform, email compliance@lumx.io.

©2026. All rights reserved.

LUMX SOCIEDADE PRESTADORA DE SERVIÇOS DE ATIVOS VIRTUAIS LTDA., a private legal entity, enrolled with the CNPJ/MF under No. 42.887.120/0001-00 ("Lumx"), acts as a virtual asset service provider and is in the process of adapting to the regulatory regime for Virtual Asset Service Provider Companies (SPSAV), pursuant to Central Bank of Brazil (BCB) Resolution No. 520/2025, currently being subject to the transition regime set forth in Article 88 thereof.


Lumx US OP LLC ("Lumx") is a financial technology and payments infrastructure company. Lumx US OP LLC is a Money Service Business (MSB) registered with the Financial Crimes Enforcement Network (FinCEN) (MSB #31000316459619). Lumx is not a state-licensed money transmitter and does not, in its own capacity, engage in the provision of regulated money transmission services. All such regulated activities are conducted exclusively through, and under the licenses of, duly authorized financial-institution partners.


Lumx is not a bank, financial institution, payment institution, or custodian of client funds. Certain services made available through the Platform may be provided by duly authorized and regulated third-party partners, in accordance with applicable laws and regulations.

Please refer to Lumx’s Terms of Use and Privacy Notice for further information regarding the conditions governing the use of the Platform and the processing of your personal data.