Compliance Overview

Preliminary document. This page is a public overview of our compliance posture. Final compliance documents — including the Cardholder Agreement, E-Sign Disclosure, Data Processing Agreement, and detailed Acceptable Use Policy — are subject to outside counsel review before card features launch. Last updated: 2026-05-06.

1. Who we are

LPJ Services LLC, a Florida limited liability company, operates OpenClaw to Business at clawtobusiness.com. Our compliance program covers three integrated capabilities:

• Digital Presence & Customer Acquisition — websites, AI assistants, lead capture, organic SEO, paid traffic management.
• Business Infrastructure — company formation, registered agent service, EIN, compliance filings (white-label through Northwest Registered Agent / Corporate Tools API).
• Controlled Operational Expense Management — virtual business expense cards and operational spending controls (coming soon — gated by outside counsel review and sponsor bank contract).

2. Business verification (KYB)

Access to operational expense card features (when launched) requires Know-Your-Business (KYB) verification. KYB collects, verifies, and ongoing-monitors the legal entity submitting the application:

• Legal entity name, EIN, business address, industry classification (NAICS / MCC).
• Beneficial ownership disclosure for any natural person owning 25% or more of the legal entity (FinCEN Beneficial Ownership Information Reporting under the Corporate Transparency Act).
• Control person identification (the natural person with significant responsibility for managing the entity).
• Documentary evidence: articles of incorporation or organization, EIN letter, ownership certificates.

KYB verification is performed through third-party identity verification providers under commercial agreements that prohibit data sale or repurposing.

3. Identity verification (KYC)

Beneficial owners and control persons of businesses applying for expense card features are subject to Know-Your-Customer (KYC) verification:

• Legal name, date of birth, residential address.
• Government-issued identification (driver's license, passport, or state ID).
• Tax identifier (SSN, ITIN, or foreign equivalent depending on jurisdiction).
• Database and biometric verification through third-party providers.

4. Sanctions screening

All beneficial owners, control persons, and applicant businesses are screened against:

• U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list.
• Other sanctions lists relevant to U.S. law (FinCEN, State Department, Commerce Department).
• Politically Exposed Person (PEP) lists where applicable.

Screening occurs at onboarding and continuously throughout the relationship. A positive match results in immediate suspension and escalation to law enforcement where required.

5. Transaction monitoring

When operational expense card features launch, transactions are monitored in real time and post-transaction by automated systems plus human compliance review for:

• Patterns inconsistent with declared business operations.
• Indicators of money laundering, fraud, or terrorist financing.
• Velocity, geography, and merchant category anomalies.
• Blocked merchant categories per program rules and acceptable use restrictions.

Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) are filed with FinCEN as required by the Bank Secrecy Act. Per BSA tipping-off prohibitions, we cannot disclose to a customer that a SAR has been filed.

6. Fraud prevention

Fraud prevention layers include device fingerprinting, behavioral analytics, transaction risk scoring, multi-factor authentication for sensitive operations, and card-level controls (per-card limits, MCC blocking, geographic restrictions, time-of-day rules).

7. Acceptable use restrictions

OpenClaw to Business operational features may be used only by verified businesses for legitimate business operations. Prohibited uses include but are not limited to:

• Personal, family, or household use (consumer use).
• Lending, factoring, or extending credit without applicable licenses.
• Payroll disbursement as a substitute for compliant payroll systems.
• Retail scalping (purchasing in-demand inventory for resale).
• Free-trial abuse using disposable card credentials.
• Stored-value resale or program-arbitrage activities.
• Cryptocurrency trading or speculative crypto activities.
• Gambling, adult content, cannabis, or other categories blocked by sponsor bank policy.
• Any activity that violates applicable federal, state, or local law.

See the dedicated Acceptable Use Policy for the full list.

8. Operational controls

Internal operational controls include:

• Designated Compliance Officer responsible for the BSA/AML program.
• Written compliance program reviewed annually.
• Annual BSA/AML training for officers and employees.
• Independent compliance program review.
• Audit log retention for transactions, account changes, and compliance events.
• Vendor due diligence procedure for sub-processors.

9. Data privacy

Identity verification and transaction data are protected by encryption at rest and in transit, isolated per business, and shared only with the third-party providers required to deliver the service. See the Privacy Policy and the Sub-Processors page for the complete vendor list and roles.

10. Business-only restriction

Operational expense card features (when launched) may be used only by verified businesses for business operational expenses. Personal, family, or household use is prohibited and will result in card suspension. Cards are not bank accounts, are not consumer financial products, do not pay interest, and cannot be used for personal expenses.

11. Disclosures (when card features launch)

When operational expense card features launch, the following disclosures will appear prominently across the platform:

• Issuer attribution: "Cards issued by [Sponsor Bank], pursuant to license from Visa or Mastercard."
• "Business use only. Not a deposit account. Not FDIC-insured."
• Cardholder Agreement, E-Sign Disclosure, and Data Processing Agreement available before account opening.

12. Contact

For compliance inquiries, contact: [email protected]

For privacy inquiries, contact: [email protected]

For general inquiries, contact: [email protected]

LPJ SERVICES LLC
6800 NW 39th Ave
Coconut Creek, FL 33073
United States