AML Policy

Anti-Money Laundering (AML) E-commerce Policy

1. Purpose

Lariany LLC (“Lariany,” “we,” “our”) is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (“AML”) Policy outlines the principles and procedures we follow to ensure compliance with applicable U.S. laws and industry best practices in connection with our e-commerce fine jewelry business.

2. Scope

This policy applies to all online sales conducted through Lariany’s website and approved sales channels, all customers and transactions, and all employees, contractors, and third-party service providers involved in order processing, payments, or fulfillment.

3. Regulatory Framework

Lariany operates in accordance with applicable U.S. laws and regulations, including the Bank Secrecy Act (BSA), U.S. Anti-Money Laundering regulations, Office of Foreign Assets Control (OFAC) sanctions programs, and applicable state and federal consumer and commerce laws.

4. Risk-Based Approach

Lariany applies a risk-based approach to identify and mitigate money-laundering risks, considering transaction value, payment methods, customer location, and purchasing behavior.

5. Customer Due Diligence (CDD)

Lariany may collect and verify customer information such as full name, billing and shipping address, contact details, and payment information processed through secure providers.

6. Prohibited Transactions

Lariany does not permit transactions involving sanctioned individuals, anonymous payments, or requests to misrepresent transaction details.

7. Transaction Monitoring

Transactions are reviewed for unusual or suspicious activity and may be delayed, canceled, or reported as required.

8. Recordkeeping

Records related to transactions and compliance are maintained in accordance with legal and business requirements.

9. Reporting Suspicious Activity

Suspicious activity may be investigated internally and reported to appropriate parties or authorities where required.

10. Third-Party Providers

Lariany works with reputable third-party service providers expected to maintain compliance standards.

11. Training

Relevant personnel are expected to be familiar with this policy and AML risk indicators.

12. Policy Review

This policy is reviewed periodically and updated as necessary.

13. Contact

Questions regarding this policy may be directed to info@lariany.com.