Anti-Money-Laundering & Know-Your-Customer Policy
This policy explains how Assukna Real Estate Lebanon SARL (the “Company”, “we”) verifies the identity of the people who use the Assukna platform (the “Platform”) and how we guard against money laundering, terrorist financing, sanctions breaches and fraud. It expands on section 4 of our Terms of Service and should be read alongside our Privacy Policy.
Verification is mandatory. You cannot deposit funds, invest in a project, or withdraw money from the Platform until your identity has been verified.
1. Our position
The Company is registered with the Beirut Commercial Register and is not licensed or supervised by a financial regulator — see our Trust & Legal Centre for the full statement of our regulatory status. We nonetheless apply the controls set out below, because knowing who is on the Platform is fundamental to the integrity of every project on it and to the safety of the other investors alongside you.
Money laundering and terrorist financing are criminal offences in Lebanon under Law No. 44 of 24 November 2015 (Fighting Money Laundering and Terrorist Financing), and the obligations that law creates — to identify customers, to keep records, and to report suspicion to the Special Investigation Commission at the Banque du Liban — apply irrespective of whether a business is supervised by a financial regulator. This policy is written to meet that standard. Real-estate transactions and dealings in property are expressly within the scope of that law, and we also observe Lebanon’s restrictions on cash settlement of property transactions.
2. Customer due diligence
Before an account may transact, we collect and verify:
- Your full legal name, date of birth and nationality.
- A government-issued photographic identity document (passport, national identity card or equivalent).
- A liveness check confirming that the person presenting the document is the person opening the account.
- Your country of residence and contact details.
Identity verification is performed by Sumsub, a specialist identity verification provider. Documents and biometric data are submitted directly to the provider; the Company receives the verification outcome and the associated identity data necessary to maintain its records.
3. Screening
Every verified user is screened against international sanctions lists, and for status as a politically exposed person or a close associate of one. Screening is performed at onboarding and repeated periodically. A positive match does not automatically bar an account, but it triggers enhanced review and, where appropriate, senior approval before the account may transact.
4. Source of funds
We may ask you to evidence the source of the funds you are investing, particularly for larger amounts, for activity that does not match the profile you gave us at onboarding, or where screening has flagged your account for enhanced review. We may decline or reverse a deposit where a satisfactory explanation is not provided.
5. Enhanced due diligence
Enhanced due diligence — additional documentation, additional questions and senior sign-off — applies where: the user is a politically exposed person or an associate of one; the user is resident in, or funds originate from, a higher-risk jurisdiction; the transaction is unusually large or structured to appear otherwise; or the pattern of activity is inconsistent with the stated purpose of the account.
6. Payments and payment channels
Deposits are accepted only through our supported payment processors and are credited only after the processor has confirmed the payment to us with a cryptographically verified message, with the amount independently reconciled. Third-party payments are not accepted: funds must come from an account or wallet in your own name. Withdrawals are returned to you and are reviewed before release.
7. Ongoing monitoring
Account activity is monitored on an ongoing basis for patterns characteristic of laundering or fraud — including rapid deposit and withdrawal without a corresponding investment, transactions structured to stay beneath review thresholds, and activity inconsistent with the user’s stated profile. Every transaction on the Platform is recorded in an immutable audit trail.
8. Prohibited users and activity
We do not open or maintain accounts for: persons appearing on applicable sanctions lists; persons resident in jurisdictions we are unable to serve; anonymous or fictitious-name accounts; or persons acting as a front for an undisclosed third party. Using the Platform to launder money, to finance terrorism, to evade sanctions or to commit fraud is strictly prohibited.
9. Refusal, suspension and termination
We may refuse to open an account, decline a transaction, suspend an account, freeze a withdrawal or terminate the relationship where verification fails, where information requested is not provided, where screening produces an unresolved match, or where we suspect financial crime. Where we are prohibited by law from explaining our reasons, we will not do so.
10. Reporting
Where we identify activity that we suspect involves the proceeds of crime or the financing of terrorism, we will report it to the Special Investigation Commission (SIC) at the Banque du Liban — Lebanon’s financial intelligence unit and the authority designated to receive such reports under Law No. 44/2015 — and to any other competent authority where the law requires it. We will cooperate fully with any resulting investigation, and we will comply with any freezing or information order the SIC issues.
We will not tell you that we have made a report. Tipping off the person concerned is prohibited by law. We may also decline to explain why an account has been restricted, or why a transaction has not proceeded, where explaining would amount to tipping off. This is the one circumstance in which our normal commitment to tell you the reason for a decision does not apply.
11. Record keeping
Identity records, verification results, screening outcomes and transaction records are retained for the period required by applicable law and, in any event, for no less than five years after the end of the relationship. See our Privacy Policy for how this data is handled and what rights you have over it.
12. Governance and training
Responsibility for this policy sits with the Company’s management. Staff with access to accounts, payments or verification decisions receive training on financial-crime risk, and this policy is reviewed at least annually and whenever there is a material change to our services or to applicable law.
13. Contact
Questions about this policy, or about a verification decision affecting your account, may be sent to compliance@assukna.com.