Luso Automotive (“we”, “our”, or “us”) is committed to the highest standards of compliance with applicable anti-money laundering (AML) laws and regulations in Portugal and the European Union. This Anti-Money Laundering Policy outlines our procedures to detect, prevent, and report suspicious activities related to money laundering, terrorist financing, and other financial crimes.

1. Purpose

This policy is designed to:

• Prevent the use of Luso Automotive for money laundering or terrorist financing

• Comply with all relevant laws including the Portuguese AML Law and EU Directive (EU) 2018/843 (5th AML Directive)

• Promote a culture of compliance and integrity within our operations

2. What is Money Laundering?

Money laundering is the process of disguising the origin of illegally obtained money to make it appear legitimate. It typically involves three stages:

1. Placement – introducing illegal funds into the financial system

2. Layering – moving funds to obscure their origin

3. Integration – reintroducing funds into the economy as apparently legitimate assets

3. Know Your Customer (KYC)

We perform KYC checks on all clients before entering into any sales or import agreement. This may include:

• Verifying personal identity (e.g., passport, national ID, driver’s license)

• Confirming address (e.g., utility bill, lease agreement)

• For companies: collecting registration documents, ownership structure, and legal representative info

Additional checks may apply in high-risk cases, such as:

• Cash purchases

• International transfers

• Unusual or complex transactions

4. Risk Assessment

We assess client risk based on:

• Geographic location

• Nature of the transaction

• Source of funds

• Whether the client is a politically exposed person (PEP)

High-risk clients or transactions may be subject to enhanced due diligence (EDD).

5. Accepted Payment Methods

To reduce the risk of financial crime, we only accept payments through secure, traceable channels:

• Bank transfers (preferably from accounts in the customer’s name)

• Certified financing providers

• Debit or credit card (in the buyer’s name)

We do not accept:

• Large cash payments

• Third-party payments without documentation

• Cryptocurrencies

6. Monitoring & Reporting

We monitor transactions for signs of suspicious activity, such as:

• Attempts to avoid record-keeping thresholds

• Unusual patterns or inconsistencies

• Reluctance to provide identification

Suspicious transactions will be reported to the Portuguese Financial Intelligence Unit (UIF / Unidade de Informação Financeira) in accordance with national regulations.

7. Staff Training

All employees involved in client transactions receive regular AML training to:

• Recognize suspicious behavior

• Understand reporting obligations

• Maintain compliance with laws and internal policies

8. Record Keeping

We retain records of customer identification, transaction data, and AML reports for a minimum of 5 years, or longer if required by law.

9. Responsibilities

The AML Compliance Officer at Luso Automotive oversees the implementation and enforcement of this policy. You may contact them at:

Email: legal@lusoautomotive.com
Phone: +351 934 220 394

10. Policy Updates

This policy may be updated to reflect changes in the law or company procedures. The most current version will always be available on our website.