Sanctions & Risk Monitoring

Lombard utilizes TRM Labs and Elliptic Enterprises to fulfil our legal obligations, and also to develop our own enhanced risk framework beyond this baseline.

All wallet addresses (for BTC deposits, LBTC minting, and bridging LBTC between networks) are scanned against TRM for every request.

Overview of our risk framework:

• An address cannot be sanctioned by OFAC (Office of Foreign Assets Control).

• An address cannot be a close counterparty to a sanction address.

• An address cannot hold a share of funds obtained by illicit means.

In the event of interaction with Lombard via a sanctioned address, the following will occur:

• Lombard's Security Consortium will not sign for the minting of LBTC or the redemption of LBTC

• Lombard's Security Consortium will not stake relevant BTC into Babylon

• Depending on the severity of the risk event; Lombard Protocol is required to hold these funds and may only return with relevant authorization.