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LucasLINK – AML/CTF Risk Awareness & Compliance Policy (Public Summary)

Last updated: 2025

LucasLINK operates a digital-asset merchant acceptance model, allowing approved businesses and their clients to pay for LucasLINK’s own services using select supported digital assets. LucasLINK is not a Digital Currency Exchange (DCE), broker, custodian, remitter, or converter of digital assets, and does not provide exchange services of any kind.

This AML/CTF Policy outlines how LucasLINK manages the risks of money laundering and terrorism financing within the nature and scope of our services.

1. Our Service Model & AUSTRAC Position

LucasLINK accepts digital assets only as payment for our own services.
We do not:

  • exchange digital assets for fiat currency
  • convert digital assets between types
  • remit or forward digital assets on behalf of clients
  • hold or pool customer assets
  • operate accounts, wallets, or custody services
  • process withdrawals or cash-outs

Because LucasLINK does not provide exchange, conversion, remittance, or custody services, we are not a DCE and are not a reporting entity under the AML/CTF Act.

However, we recognise that digital assets carry inherent AML/CTF risks, and therefore voluntarily apply risk-based measures appropriate to our merchant acceptance model.

2. Our AML/CTF Risk Principles

LucasLINK adopts the following principles:

2.1 – Merchant-Only Acceptance

We accept digital assets only as payment for our own service invoices and only from clients who are contracting LucasLINK directly.

2.2 – No Facilitation of Third-Party Transfers

We do not support transfers:

  • between unrelated parties
  • to third-party wallets
  • on client instructions (no forwarding)

All digital assets received are treated as payment to LucasLINK.

2.3 – Fixed AUD Pricing

All service prices are set in Australian Dollars (AUD).
The digital-asset amount is fixed at the moment of payment initiation to minimise volatility-based exploitation.

2.4 – Payments Are Final

Once confirmed on-chain, payments are treated as final and non-refundable, reducing risks associated with refund laundering or layering.

3. Customer Due Diligence (CDD)

LucasLINK implements proportionate due-diligence procedures:

3.1 – Standard Transactions

For typical B2B invoices within expected value ranges:

  • We collect basic business details (ABN, contact information, domain/email validation).
  • We validate the commercial relationship between the business and its client.

3.2 – Larger or Higher-Risk Transactions

We may request additional information, such as:

  • Government-issued ID (for individuals)
  • Business ownership details
  • Nature/purpose of the transaction
  • Source of funds/source of digital assets (where appropriate)

These measures ensure we do not participate in or facilitate suspicious activity.

3.3 – Refusal of Service

LucasLINK reserves the right to decline:

  • any digital-asset payment
  • any business onboarding
  • any continuation of services

if we reasonably believe there is a risk of ML/CTF, fraud, sanctions exposure, or regulatory risk.

4. Supported Digital Assets & Networks

LucasLINK maintains a curated list of supported assets based on:

  • global liquidity
  • maturity and transparency
  • stability of network infrastructure
  • lower anonymity-enhancing features
  • security considerations

Assets with high anonymity risk, extreme volatility, or insufficient network transparency are not supported.

This list may be updated without notice as part of ongoing risk management.

5. Transaction Monitoring

Although LucasLINK is not a reporting entity, we voluntarily employ reasonable monitoring practices consistent with our service model:

5.1 – On-Chain Transaction Checks

We assess incoming payments for:

  • irregular patterns
  • known-risk mixers or obfuscation tools
  • sanctioned-address exposure
  • abnormal transfer sequences
  • suspicious behavioural patterns

5.2 – Consistency With Business Purpose

Payments must reasonably match:

  • the invoice value
  • the relationship between the business and its client
  • commercially expected patterns

Where inconsistencies arise, we may pause settlement and seek clarification.

5.3 – Suspicious or Illicit Activity

We may decline settlement and terminate services where activity appears:

  • fraudulent
  • illegitimate
  • associated with sanctions
  • associated with known illicit finance behaviour
  • deliberately obfuscated

6. Settlement Practices

All AUD settlements to B2B clients or partners:

  • are made from LucasLINK’s own business funds
  • occur only after on-chain payment confirmation
  • are paid to an Australian bank account held in the business’s legal name

This structure:

  • prevents misuse of payments as proxy remittance
  • ensures funds only flow to legitimate business entities
  • avoids custody/liquidity risks

7. Data Handling & Privacy

All personal and business information collected for AML/CTF risk management is handled in accordance with:

  • the LucasLINK Privacy Policy
  • Australian Privacy Principles (APPs)
  • reasonable security and retention practices

We only collect information necessary for risk assessments.

8. Staff Training & Operational Oversight

Although we are not a reporting entity, LucasLINK maintains:

  • periodic internal AML/CTF training
  • documented operational procedures
  • escalation pathways for suspicious activity
  • an internal compliance lead (Director-level)

This ensures consistent application of our risk-based controls.

9. Policy Review

This AML/CTF Risk Policy is reviewed:

  • at least annually
  • when regulations or AUSTRAC guidance change
  • as our business model evolves
  • as new digital-asset risks are identified

Updates may be published to reflect current standards and internal controls.

10. Contact for Compliance Matters

LucasLINK – Compliance Enquiries
Email: hello@lucaslink.com.au (placeholder)
Location: Western Australia

Prominent compliance statement

LucasLINK operates as a merchant-acceptance business and is not a digital currency exchange (DCE). We accept select digital assets only as payment for our own services. We do not provide exchange, conversion, brokerage, remittance, or custody services.

All crypto payments are final and non-refundable once confirmed on-chain. Prices are set in AUD, and the payable digital-asset amount is fixed at the time of payment initiation. LucasLINK does not offer conversion, cash-outs, or custody of client funds.

Statutory rights under the Australian Consumer Law (ACL) remain unaffected. 

See our Terms of Service for details.