Compliance Notes

Last updated: November 26, 2025

1. General Compliance Statement

Lumi Trade is a decentralized, non-custodial trading protocol that enables users to interact directly with on-chain smart contracts. Lumi Trade does not operate as a broker, custodian, financial intermediary, or money services business under traditional regulatory frameworks.

Users retain full control over their digital assets at all times. The following Compliance Notes outline how Lumi Trade approaches regulatory considerations within a decentralized architecture.


2. Non-Custodial Architecture

Lumi Trade does not:

  • Hold, manage, or custody user funds

  • Store private keys, seed phrases, or authentication credentials

  • Execute trades or make decisions on behalf of users

  • Intervene in or modify submitted transactions

  • Control assets once deposited into smart contracts

All transactions occur on a peer-to-contract basis through publicly deployed smart contracts. As Lumi Trade is fully non-custodial, regulatory obligations applicable to custodial entities—such as client fund segregation or capital adequacy rules—are not relevant to this model.


3. No Client Accounts or KYC Custody Requirements

Lumi Trade does not create custodial accounts for users and does not collect personal identifying information such as passports, addresses, banking information, or financial records.

Users access the interface via self-custodial wallets or optional Privy email login for UI personalization only.

Since Lumi Trade does not custody funds or maintain financial accounts, traditional KYC/AML requirements for financial intermediaries may not apply. However, the platform may apply jurisdiction-based access restrictions when required by law.


4. Jurisdictional Restrictions

The availability of Lumi Trade may vary depending on local regulatory requirements. Access may be restricted for users located in:

  • Sanctioned or embargoed jurisdictions

  • Regions listed under OFAC or similar sanction regimes

  • Locations where decentralized derivatives platforms are restricted

IP filtering or geographic routing may be used for compliance purposes, but such methods cannot guarantee precise identification of user location.

Users are responsible for ensuring their use of Lumi Trade complies with applicable local laws.


5. Decentralized Smart Contract Operations

Lumi Trade smart contracts:

  • Are publicly visible and verifiable

  • Operate autonomously without manual intervention

  • Cannot be altered except through approved governance mechanisms

  • Are permissionless to interact with

Lumi Trade contributors do not supervise trading activity, match market participants, or intermediate transactions. Because the protocol functions autonomously, it may fall outside certain licensing frameworks that apply to traditional exchanges.


6. No Financial Advice or Investment Services

Lumi Trade does not provide:

  • Trading, financial, or investment advice

  • Portfolio management or discretionary trading services

  • Tax or legal guidance

  • Guarantees of profit or performance

All information on the interface, documentation, or communication channels is strictly informational. Users are solely responsible for evaluating the risks of digital asset trading.


7. Protocol Fees and Revenue

Fees on Lumi Trade—including ZFP profit-based fees, spreads, or liquidity-related fees—are:

  • Automatically executed by smart contracts

  • Transparent and auditable on-chain

  • Not manually controlled by any centralized entity

Fee distribution mechanisms may support protocol sustainability, rewards programs, or future DAO operations. These mechanisms do not represent equity, dividends, or securities rights.


If launched, the $LUMI token may serve as a utility token for governance, rewards, incentives, or fee benefits within the protocol.

$LUMI is not intended to represent:

  • Equity

  • Ownership interest

  • Debt

  • A claim to revenue

  • A security

Regulatory interpretations may vary by jurisdiction, and Lumi Trade will adapt where appropriate.


9. AML / Sanctions Compliance

As a decentralized protocol, Lumi Trade cannot monitor or supervise individual user transactions. However, Lumi Trade may:

  • Restrict access from sanctioned regions

  • Integrate on-chain risk or compliance tools

  • Apply UI-level blocklists or allowlists

  • Limit certain features to comply with legal obligations

Users are responsible for ensuring their wallet, location, and activity comply with anti-money laundering and sanctions regulations.


10. External Integrations

Lumi Trade relies on third-party infrastructure such as:

  • Wallet providers

  • Oracle networks

  • Node/RPC providers

  • Analytics tools

  • Smart contract verifiers

  • Cross-chain bridges

These external services operate under their own policies and compliance frameworks. Lumi Trade is not responsible for the compliance or operational decisions of third-party systems.


11. Governance & Protocol Upgrades

Future decentralized governance using $LUMI may enable community decision-making over:

  • Contract upgrades

  • Trading parameters

  • Fee models

  • Supported assets

  • Security or risk adjustments

Governance processes may be executed transparently on-chain and align with compliance best practices for open decentralized systems.


12. User Responsibility

Users must:

  • Comply with all applicable laws and regulations

  • Understand the risks involved in interacting with decentralized protocols

  • Avoid prohibited behaviors such as fraud or sanctions evasion

  • Use the platform responsibly and lawfully

Lumi Trade is not responsible for user actions that may violate local laws.


13. No Guarantee of Global Regulatory Compliance

Decentralized protocols operate across multiple jurisdictions and may not neatly align with traditional regulatory categories.

Lumi Trade cannot guarantee regulatory compliance or service availability in all regions. Users acknowledge that:

  • Regulatory environments may evolve rapidly

  • DeFi may be subject to new rules or enforcement actions

  • Access to Lumi Trade may change over time


14. Contact Information

For compliance-related inquiries: 📧 [email protected]

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