Anti-Money Laundering (AML) and Counter-Terrorist Financing Policy
1.Purpose
This Policy describes the measures used by LUST INNOVATION LTD (the “Operator”) to reduce the risk that GeneratePorn is used for money laundering, terrorist financing, sanctions evasion, fraud or other illicit financial activity.
The Operator is an online content and technology business, not a bank or payment institution. This Policy does not represent that the Operator is itself a regulated financial institution or a “designated person” for every purpose under Irish anti-money-laundering legislation. Where legal AML obligations apply directly to the Operator, they will be followed. Separately, payments may be processed by regulated third-party providers that apply their own KYC, AML and sanctions controls.
The Operator maintains a risk-based approach informed by applicable Irish law, EU sanctions requirements, contractual obligations imposed by payment providers and relevant international standards.
2.Relevant Framework
Where applicable, the Operator takes account of:
- the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended;
- applicable Irish legislation implementing EU AML requirements;
- EU and UN financial sanctions;
- guidance and requirements of competent Irish authorities where applicable; and
- Financial Action Task Force (FATF) standards and risk indicators where relevant.
3.Payment Controls
GeneratePorn processes payments through third-party payment providers and does not offer peer-to-peer user transfers.
The Operator may:
- use payment providers that maintain appropriate KYC/AML controls;
- refuse or restrict transactions where risk indicators are present;
- apply velocity, amount, geographic, payment-method and account-behaviour checks;
- request additional information where reasonably necessary; and
- suspend or terminate accounts associated with suspected fraud, laundering, sanctions evasion or other illicit activity.
4.Customer Identification and Enhanced Review
General use of GeneratePorn may not require identity verification in every case. The Operator may nevertheless request identity or source-of-funds information where justified by risk, law, a regulator, law-enforcement authority or payment-provider requirement.
Information requested may include:
- government-issued identification;
- proof of address;
- information concerning source of funds or source of wealth;
- clarification of transaction purpose; or
- other information reasonably required to resolve a compliance concern.
Access to some Services or transactions may be restricted until requested information is provided and satisfactorily reviewed.
5.Transaction Monitoring
The Operator and/or its payment providers may monitor transaction and account activity for indicators including:
- unusual transaction size or frequency;
- repeated failed or reversed transactions;
- structuring or attempts to avoid limits;
- inconsistent geographic or account information;
- suspicious use of multiple accounts or payment instruments;
- transactions connected with sanctioned persons or jurisdictions; and
- other behaviour inconsistent with normal lawful use of the Services.
Automated controls may be supplemented by manual review.
6.Financial Sanctions
The Operator will not knowingly make funds or economic resources available in breach of applicable EU or UN financial sanctions.
Where appropriate, the Operator or its payment providers may screen transactions, customers or counterparties against applicable sanctions information and may block or refuse activity where a potential match requires investigation.
7.Suspicious Activity and Reporting
Where suspicious activity is identified, the Operator may restrict transactions or accounts, preserve relevant information, request additional verification and cooperate with payment providers or competent authorities.
Where the Operator is subject to a statutory reporting obligation under Irish AML law, suspicious transaction reporting will be made to the appropriate Irish authorities, including FIU Ireland within An Garda Síochána and the Revenue Commissioners as required by law. Where the Operator is not itself the reporting entity, it may instead provide relevant information to the regulated payment provider or other entity responsible for the statutory report.
Users will not be informed of a report where doing so would breach a legal prohibition on tipping off or otherwise interfere with an investigation.
8.Compliance Responsibility
The Operator assigns responsibility for administration of this Policy and may designate a specific AML or compliance officer where required by law, contract or operational risk.
Compliance contact: support@generateporn.ai
9.Training and Internal Controls
Personnel who handle payments, fraud, compliance or relevant user information may receive training appropriate to their role, including recognition of suspicious activity, escalation procedures, sanctions risk, confidentiality and record handling.
10.Record Keeping
Records reasonably required for fraud prevention, payment compliance, investigations and legal obligations may be retained for the period required by applicable law and legitimate operational need.
Where Irish AML record-retention requirements apply to the Operator as a designated person, relevant records will be retained for at least the legally required period, including the five-year period provided for under section 55 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, subject to applicable amendments and lawful extensions.
Personal data retained for compliance purposes is handled in accordance with applicable data-protection law, including the GDPR and the Irish Data Protection Act 2018 where applicable.
11.Review
This Policy may be reviewed when laws, payment methods, risk exposure, sanctions requirements, provider obligations or the Services materially change.