Prohibition of Third-Party Account Opening
Last updated: July 1, 2026
To safeguard the integrity of our identity verification process and strictly comply with applicable anti-money laundering (AML) laws, counter-terrorism financing (CTF) regulations, and financial compliance standards, Sumulux LLC strictly prohibits any third party from opening, registering, applying for, or operating a Sumulux account or accessing card services on behalf of another individual or legal entity. All accounts must be opened, registered, and operated directly by the verified account holder in person.
1. Personal Identity Verification (KYC)
Each user must personally complete all identity verification (Know Your Customer / KYC) procedures, including providing their own original personal data, government-issued identification documents, proof of address, and biometric information (such as real-time facial recognition/liveness checks), where applicable.
2. Unauthorized Use of Identification
No individual or entity shall use another person's or entity's personal data, identification documents, credentials, or financial information to open, attempt to open, or operate a Sumulux account without that individual personally participating in and consenting to the registration and verification process.
3. Prohibition of Intermediaries & Agents
Any agent, intermediary, broker, or third party is expressly prohibited from creating accounts, submitting applications, or completing identity verification steps on behalf of any prospective or existing user.
4. Ongoing Verification & Audit Rights
Sumulux LLC reserves the right to conduct ongoing identity verification, re-verification, and compliance audits at any time during the active period of your account, including but not limited to: requiring you to re-submit updated identification documents or present additional proof of identity/address; requiring you to complete real-time, mandatory identity verification via video call, biometric authentication, or secondary authorization steps; cross-referencing your account activity, IP addresses, login records, device fingerprints, and behavioral transaction patterns against the identity information on file to detect any anomalies or unauthorized access; and requesting formal confirmation of your operational background or source of funds. You agree to cooperate fully and promptly with any such verification requests. Failure to comply with a verification request within the timeframe specified by Sumulux LLC shall constitute grounds for immediate account restriction, suspension, or termination.
5. Enforcement & Remedial Actions
Where Sumulux LLC detects, identifies, or reasonably suspects that an account has been opened, registered, or is being operated by a third party in violation of this Policy, Sumulux LLC shall be entitled, at its sole discretion and without prior notice, to: immediately restrict, suspend, or block access to the account, digital wallet, mobile application, and associated API services; freeze any funds, card balances, or assets held in the account pending formal investigation; terminate the account relationship permanently and revoke/cancel all associated Virtual or Physical Visa/Mastercard cards without refund of processing fees; decline to process any pending, recurring, or future transactions associated with the account; report the suspected violation, along with relevant user data, to applicable regulatory authorities, financial intelligence units, or law enforcement agencies; retain all personal data, system logs, and transaction records for legal proceedings or regulatory reporting; and pursue formal legal action against any party involved in unauthorized third-party account opening or operation.
6. Indemnification & Liability
The registered account holder shall remain solely responsible and legally liable for any and all losses, claims, damages, liabilities, regulatory penalties, or legal consequences arising from any third-party account opening or operation conducted in violation of this provision. Sumulux LLC shall not be held liable for any financial losses or damages resulting from the enforcement of its rights under this section.