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Anti-Money Laundering, Sanctions, and Prohibited Use Policy

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Written by Theodore at Lastpack

Effective Date: May 18, 2026

Last Updated: July 15, 2026

Lotus Digital Inc. d/b/a lastpack (“lastpack,” “we,” “us,” or “our”) is committed to preventing the misuse of lastpack for money laundering, terrorist financing, sanctions evasion, fraud, illegal activity, and other prohibited conduct.

This Anti-Money Laundering, Sanctions, and Prohibited Use Policy explains the standards that apply when you access or use lastpack, including our website, web application, account system, crypto payment flows, Pack-opening experiences, Vault, buybacks, shipping, rewards, promotions, customer support, and related services, collectively, the “Service.”

This Policy is incorporated into and subject to our Terms of Service. Capitalized terms not defined in this Policy have the meanings given to them in the Terms of Service.

1. Purpose of This Policy

lastpack is a collectible commerce and entertainment platform. The Service currently supports crypto payments and may involve the purchase of Packs, assignment of collectible Items, storage of Items in a Vault, buyback offers, shipping, Account Credits, rewards, and related transactions.

Because crypto payments can involve wallet addresses, public blockchain transactions, and cross-border activity, we take steps designed to reduce the risk that the Service is used for unlawful or prohibited purposes.

This Policy is designed to help us:

  • Prevent money laundering and terrorist financing

  • Screen for sanctions and restricted jurisdictions

  • Detect fraud, abuse, botting, multi-accounting, and prohibited activity

  • Protect users, lastpack, service providers, and the integrity of the Service

  • Comply with applicable laws, regulations, legal process, and service provider requirements

  • Maintain records where appropriate

  • Investigate suspicious or prohibited activity

2. No Illegal or Prohibited Use

You may not use the Service for any illegal, fraudulent, abusive, or prohibited purpose. Without limiting our Terms of Service, you agree that you will not use the Service to:

  • Launder money or disguise the source, ownership, location, or control of funds

  • Finance terrorism or extremist activity

  • Evade sanctions, trade restrictions, export controls, or restricted jurisdiction rules

  • Use funds derived from illegal activity

  • Use stolen, hacked, compromised, or unauthorized wallets or funds

  • Use the Service on behalf of another person, entity, or undisclosed beneficial owner

  • Use a VPN, proxy, remote desktop, false address, false phone number, or other method to evade location, identity, sanctions, or eligibility checks

  • Create or operate multiple accounts to evade limits, restrictions, reviews, bans, or controls

  • Abuse promotions, rewards, referrals, buybacks, shipping, or Account Credits

  • Engage in botting, scraping, automation, exploit abuse, or manipulation of the Service

  • Use the Service for market manipulation, wash activity, circular transactions, or artificial transaction volume

  • Submit false, misleading, incomplete, or fraudulent information

  • Interfere with our compliance, risk, fraud, or security systems

  • Attempt to reverse, dispute, claw back, or invalidate a payment after receiving value, unless permitted by law and made in good faith

3. Restricted Jurisdictions and Sanctions

You may not access or use the Service if you are located in, ordinarily resident in, organized under the laws of, or operating from a Restricted Jurisdiction (as defined below) or any other jurisdiction where use of the Service is prohibited by lastpack, applicable law, sanctions rules, or service provider requirements.

“Restricted Jurisdictions” means, as of the Effective Date, the following jurisdictions:

Jurisdictions subject to comprehensive U.S. sanctions:

  • Cuba

  • Iran

  • North Korea (the Democratic People’s Republic of Korea)

  • Syria

  • The Crimea, Donetsk People’s Republic, Luhansk People’s Republic, Kherson, and Zaporizhzhia regions of Ukraine

Additional Restricted Jurisdictions:

  • Afghanistan

  • Belarus

  • Myanmar (Burma)

  • Russia

  • Venezuela

We may add or remove jurisdictions from the list of Restricted Jurisdictions at any time and without notice, including in response to changes in sanctions designations, regulatory guidance, service provider requirements, or risk-based considerations.

You may not use the Service if you are:

  • Listed on any applicable sanctions, restricted party, blocked person, or denied party list (including the U.S. Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals and Blocked Persons List)

  • Owned or controlled by a sanctioned person or entity

  • Acting on behalf of a sanctioned person, entity, jurisdiction, or prohibited party

  • Located in or operating from a Restricted Jurisdiction

  • Otherwise prohibited from using the Service under applicable law

We may restrict, block, suspend, or terminate access to the Service in any state, territory, country, or jurisdiction at any time.

We may use IP address, device information, phone number region, shipping address, wallet address, blockchain analytics, sanctions screening tools, fraud prevention tools, service provider information, and other data to help determine eligibility and detect restricted activity.

4. Crypto Payments and Blockchain Screening

The Service currently uses crypto payment flows. When you make a crypto payment or otherwise interact with crypto-related features, we or our service providers may review wallet addresses, transaction hashes, token type, network, transaction amount, transaction timing, transaction history, and related blockchain information.

We may use blockchain analytics, sanctions screening, fraud prevention, wallet risk scoring, and other compliance tools to help identify:

  • Sanctioned wallets or counterparties

  • Wallets associated with hacks, theft, scams, ransomware, darknet markets, terrorist financing, human trafficking, child exploitation, or other illegal activity

  • Mixers, tumblers, peel chains, chain-hopping, obfuscation techniques, or high-risk transaction patterns

  • Structuring, layering, circular activity, or suspicious flow of funds

  • Restricted jurisdiction exposure

  • Unusual activity inconsistent with ordinary use of the Service

  • Attempts to evade transaction limits, account restrictions, or compliance controls

Blockchain transactions may be public by nature. We do not control public blockchains, blockchain explorers, wallet providers, or third-party analytics providers.

5. No Standard KYC for Ordinary Account Creation

We do not currently require standard Know Your Customer verification, government-issued identification, or live selfie verification as part of ordinary account creation.

However, we may require additional information, documentation, verification, or review in specific cases, including if we believe it is necessary for:

  • Fraud prevention

  • Sanctions screening

  • Restricted jurisdiction review

  • Suspicious activity review

  • Buyback review

  • Shipping review

  • Account recovery

  • Dispute resolution

  • Abuse prevention

  • Legal compliance

  • Law enforcement or regulatory requests

  • Service provider requirements

  • Enforcement of our Terms of Service or this Policy

Additional information may include name, date of birth, address, phone number, email address, wallet address, transaction history, proof of wallet control, proof of source of funds, shipping information, government-issued identification, selfie or live image verification, business information, or other information reasonably needed to complete the review.

Failure to provide requested information may result in account restrictions, delayed transactions, canceled transactions, denied shipments, denied buybacks, suspended access, or account termination.

6. Transaction Reviews, Holds, and Restrictions

We may review, delay, hold, restrict, reject, reverse, cancel, or refuse any transaction, Pack purchase, Account Credit purchase, buyback, reward, shipment, or other activity if we believe it may involve prohibited activity, fraud, sanctions risk, restricted jurisdiction exposure, service provider restrictions, legal risk, or violation of our Terms.

We may take action before, during, or after a transaction, including after a Pack has been purchased, an Item has been assigned, a buyback has been offered, or a shipment has been requested.

Actions we may take include:

  • Blocking or rejecting crypto payments

  • Refusing to credit an account

  • Delaying or canceling Pack purchases

  • Canceling or reversing Account Credits

  • Voiding rewards, promotions, or referral benefits

  • Delaying or denying buybacks

  • Delaying or denying shipments

  • Requiring additional verification

  • Suspending or terminating an account

  • Freezing or restricting activity pending review

  • Offsetting amounts owed to lastpack

  • Reporting activity to service providers, law enforcement, regulators, or other appropriate parties

  • Taking any other action permitted by law, our Terms, or service provider requirements

7. Suspicious Activity

We may treat activity as suspicious if it appears unusual, inconsistent, high-risk, or potentially unlawful. Examples include:

  • Use of wallets linked to hacks, scams, mixers, sanctions, darknet markets, ransomware, stolen funds, or other high-risk sources

  • Attempts to obscure wallet origin, source of funds, or transaction history

  • Rapid cycling of funds through the Service

  • Repeated purchases and buybacks with no apparent collectible purpose

  • Unusual transaction size, frequency, velocity, or pattern

  • Multiple accounts using related wallets, devices, addresses, phone numbers, or payment patterns

  • Attempts to exploit pricing, FMV, buyback, rewards, referral, shipping, or promotional systems

  • Use of false or inconsistent account, shipping, or contact information

  • Use of VPNs, proxies, remote desktops, or location spoofing to access restricted jurisdictions

  • Refusal to provide requested information during a compliance, fraud, shipping, or dispute review

  • Any activity that lastpack reasonably believes creates legal, financial, reputational, operational, fraud, sanctions, or compliance risk

This list is not exhaustive. We may consider other information or behavior when reviewing activity.

8. User Responsibilities

You are responsible for ensuring that your use of the Service complies with this Policy, our Terms of Service, and applicable law.

You represent and warrant that:

  • You are using the Service only for yourself and not on behalf of any undisclosed person or entity

  • You are not subject to sanctions or other legal restrictions that prohibit your use of the Service

  • You are not located in a Restricted Jurisdiction

  • You will not use the Service to launder money, evade sanctions, finance terrorism, commit fraud, or engage in illegal activity

  • Any crypto you use with the Service is lawfully obtained and controlled by you

  • Any wallet address you use is owned or controlled by you or you are otherwise authorized to use it

  • Any information you provide to lastpack is accurate, complete, and not misleading

  • You will promptly provide information reasonably requested by lastpack for compliance, fraud prevention, shipping, dispute resolution, or enforcement purposes

9. Purchase Funds, Buybacks, Withdrawals, and Rewards

lastpack does not offer a custodial account or accept or hold customer funds for safekeeping, investment, transmission, or withdrawal on demand. Amounts paid to lastpack are purchase funds (“Purchase Funds”) provided solely to purchase Packs and other merchandise offered through the Service. Purchase Funds are not deposits, stored value, or customer assets held in custody.

Purchase Funds are non-transferable and may not be cashed out, withdrawn, or redeemed for cash. Except where applicable law requires otherwise, any refund of unused Purchase Funds must be approved by lastpack and will be returned to the original payment method rather than paid through the Cash Out feature.

Amounts owed after lastpack completes a bona fide purchase of an eligible collectible Item from a user are separate “Eligible Sale Proceeds.” “Cash Out” means a withdrawal of Eligible Sale Proceeds through the Service. Eligible Sale Proceeds represent payment owed by lastpack for merchandise purchased from the user and may be cashed out, subject to verification, transaction review, this Policy, our Terms, and applicable law. A Pack purchase by itself does not create a right to cash out or withdraw Purchase Funds.

Promotional credits, rewards, points, XP, bonuses, referral credits, goodwill credits, reimbursements, contractor or creator compensation, and other account adjustments are not themselves Eligible Sale Proceeds and may not be directly cashed out, withdrawn, or redeemed for cash. However, if a reward results in, includes, or is validly redeemed for an eligible collectible Item and lastpack later completes a bona fide purchase of that Item from the user, the resulting amount owed for the Item may become Eligible Sale Proceeds and may be cashed out, subject to any applicable turnover, eligibility, review, or program restrictions.

lastpack is not a bank, depository institution, personal wallet, or general-purpose money-transfer service. You may not use the Service as a pass-through account, wallet, exchange, off-ramp, or money-transfer service. Prohibited activity includes adding Purchase Funds primarily to cash them out or withdraw them; attempting to convert Purchase Funds directly into a Cash Out-eligible balance; sham, wash, or circular transactions; third-party funding; structuring; multiple-account abuse; and rapid purchase, buyback, and Cash Out activity without a legitimate collectible purpose.

Account Credits, buybacks, rewards, points, XP, bonuses, promotions, and other Service features may not be used to launder funds, evade restrictions, create artificial volume, exploit promotions, or conduct prohibited activity.

We may limit, cancel, reverse, expire, withhold, or deny Account Credits, buybacks, rewards, points, XP, bonuses, promotions, or related benefits if we believe they are associated with fraud, abuse, prohibited activity, suspicious activity, sanctions risk, restricted jurisdiction access, or violation of our Terms.

Buyback offers, if available, are subject to review and may be delayed, limited, denied, or canceled in accordance with our Terms and this Policy.

10. Shipping and Physical Items

We may review shipping requests for fraud, sanctions, restricted jurisdiction exposure, abuse, suspicious activity, or violations of our Terms.

We may delay, deny, cancel, or restrict shipment if:

  • The shipping address is incomplete, invalid, suspicious, or restricted

  • The shipment appears connected to fraud, abuse, sanctions risk, or prohibited activity

  • The account is under review

  • The Item is subject to inventory, title, payment, dispute, or compliance issues

  • The user fails to provide requested information

  • Shipment would violate applicable law, carrier rules, service provider requirements, or our Terms

We may share shipping information with carriers, logistics providers, insurers, tax providers, service providers, regulators, or law enforcement where appropriate.

11. Recordkeeping

We may maintain records related to accounts, crypto payments, wallet addresses, blockchain transactions, Pack purchases, Vault activity, buybacks, rewards, shipping, disputes, fraud reviews, sanctions reviews, compliance reviews, and enforcement actions.

We may retain these records for as long as reasonably necessary to operate the Service, comply with law, satisfy service provider requirements, resolve disputes, prevent fraud, prevent repeat abuse, respond to legal process, enforce our Terms, and protect lastpack, users, and others.

Our data retention practices are described further in our Privacy Policy.

12. Reporting and Cooperation

We may report suspicious, prohibited, fraudulent, or unlawful activity to service providers, regulators, law enforcement, or other appropriate parties where permitted or required by law.

We may cooperate with subpoenas, court orders, legal process, regulatory requests, law enforcement requests, service provider reviews, fraud investigations, sanctions reviews, and other lawful requests.

We are not required to notify you before making a report, preserving records, restricting an account, delaying a transaction, or cooperating with a request where doing so would be prohibited, impractical, harmful, or inconsistent with law, security, fraud prevention, or compliance needs.

13. Policy Updates

We may update this Policy from time to time. If we make material changes, we may notify you by posting the updated Policy on the Service, updating the “Last Updated” date, sending an email, providing an in-app notice, or using another reasonable method.

Your continued use of the Service after an updated Policy becomes effective means you acknowledge the updated Policy.

14. Contact

If you have questions about this Policy, contact us at:

lastpack

Lotus Digital Inc.

131 Continental Dr, Suite 305, City of Newark, County of New Castle, Delaware 19713

Email: [email protected]

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