Lois Bank – Company Policy Manual

August 2025

Introduction

This Company Policy Manual establishes the guiding framework under which Lois Bank operates as a global e-banking institution. It applies to all customers, employees, contractors, and partners, covering both fiat and digital asset services (including USDT stablecoin deposits/withdrawals, loans, and virtual credit cards).

Lois Bank aspires to operate with the standards of tier-one banks worldwide, embedding regulatory compliance, financial integrity, risk management, and customer protection in all activities.

1. Purpose & Scope

The manual sets forth Lois Bank’s governance framework, including:

• Deposits & withdrawals (fiat + stablecoins).

• Lending products (Business, Startup, Development).

• Investment products (FDR, DPS).

• Virtual credit card issuance & management.

• Cybersecurity, employee ethics, and governance.

2. Regulatory Compliance

Lois Bank complies with:

• FATF Recommendations

• EU AML Directives (5th & 6th)

• GDPR (data protection)

• OFAC & UN sanctions programs

• Local banking and VASP requirements

The Bank enforces AML, CTF, KYC, KYT, and Travel Rule compliance across all products and services.

3. Know Your Customer (KYC)

• Verification partners: Persona and/or Sumsub.

• Requirements: Government-issued ID, proof of address, biometric verification.

• EDD applied to: PEPs, high-value accounts, and high-risk jurisdictions.

• Ongoing monitoring and periodic re-verification are mandatory.

4. Know Your Transactions (KYT)

• Tools used: Elliptic & Crystal Intelligence.

• All fiat and crypto transactions are screened for:

  • Sanctions exposure.

  • Darknet links, mixers, or suspicious wallets.

  • High-risk jurisdictions.

• Transactions are risk scored, and escalated alerts may result in account freezes or SAR filings.

5. AML & CTF

• Zero-tolerance policy for illicit finance.

• SARs (Suspicious Activity Reports) filed with FIUs.

• Annual AML/CTF training for staff.

• Regular third-party compliance audits.

6. Deposits Policy

• Supported: USD (bank, PayPal), stablecoins (USDT TRC20, CoinPayments).

• Min: $5 | Max: $1,000,000 per transaction.

• Processing: Instant (internal), up to 24h (external).

• All deposits undergo compliance screening.

7. Withdrawal Policy

• OTP + 2FA mandatory.

• Beneficiary accounts/wallets must be verified.

• Wire transfers require IBAN + SWIFT.

• Processing: Instant (internal), 24h (external).

• Fees: 0.5% + $1 for wires.

• The Bank reserves the right to change the fees.

8. Deposit & Withdrawal Rules

1. Deposits/withdrawals only permitted for verified accounts.

2. Suspicious transactions may be delayed, frozen, or reported.

3. Customers are prohibited from using Lois Bank to facilitate:

• Illegal activity.

• Sanction evasion.

• Fraudulent transactions.

Lois Bank reserves the right to adjust limits based on risk tier.

Users are responsible for ensuring correct account/wallet details — Lois Bank is not liable for losses due to errors.

9. FDR & DPS Products

• FDR: Long-term fixed deposits with fixed interest.

• DPS: Installment-based savings plans.

• Early withdrawals may incur penalties.

• Subject to AML/KYC monitoring.

10. Loans Policy

• Offered: Business, Startup, Development Loans.

• Require full KYC, credit checks, and financial disclosure.

• Proceeds must be used for lawful purposes only.

• Loan misuse leads to termination & legal action.

11. Virtual Credit Cards

• Issued to verified customers only.

• Work like credit cards, with top-up & online purchase functionality.

• Limits depend on account tier.

• All transactions screened under AML/KYT rules.

12. Cardholder Responsibilities

1. Customers must safeguard card details (Lois Bank will never request 2FA codes).

2. Card misuse for fraud, gambling, or illicit purposes is strictly prohibited.

3. Lost or stolen cards must be reported immediately.

4. Cardholders are responsible for reviewing monthly statements and reporting discrepancies.

5. Chargebacks and disputes must be filed within 30 days.

13. Risk Management

• Market risk (crypto volatility, stablecoin de-pegging).

• Liquidity risk (withdrawal delays).

• Operational risk (system downtime).

• Cyber risk (hacking, malware).

• Compliance risk (regulatory changes).

14. Cybersecurity Policy

• Multi-layered security architecture (encryption, firewalls, intrusion detection).

• Mandatory 2FA for all users.

• Regular penetration testing and security audits.

• Employees follow strict IT access protocols.

• Customers are advised:

  • Use strong passwords.

  • Avoid phishing links.

  • Regularly monitor accounts.

15. Customer Support & Transparency

• Support available 24/7 via chat, email, ticketing.

• Complaints are tracked and escalated systematically.

• Transparency: All fees and policies are published online.

16. Governance & Oversight

• Compliance Officer, Data Protection Officer, Internal Audit Committee.

• Independent auditors engaged annually.

• The Board holds final responsibility for oversight.

17. Employee Training & Ethics

• All employees undergo annual AML, CTF, cybersecurity, and ethics training.

• Prohibitions: Insider trading, corruption, bribery, misuse of client data.

• Whistleblowing channel for staff to report misconduct.

• Breaches result in disciplinary action or termination.

18. Policy Review

• Reviewed quarterly.

• Updated for regulatory changes, industry standards, or internal risk reviews.

• Customers and employees are bound by the latest version that will be posted on the website of https://loisbank.com/ .