Lumanu Compliance Obligations

Lumanu Compliance Obligations

When you pay through Lumanu, Lumanu becomes your vendor, and the people you pay become Lumanu’s vendors. Lumanu handles onboarding, verifying identities, sanctions and watchlist screening, collecting and validating tax forms, and year-end tax filings.

Lumanu’s approach changes who carries compliance obligations. Your company is not the reporting party, does not own vendor verification, and does not handle support for failed payments. This page lists which obligations Lumanu takes on and which stay with you.

What Lumanu takes on

Obligation

What Lumanu does

Identity verification

Identity verification

Vendors complete identity and phone verification at onboarding. A vendor who has not cleared both cannot be paid.

Business entity verification

Business entity verification

Lumanu checks business information and TIN against the entity the vendor declares.

Sanctions screening

Sanctions screening

OFAC and AML watchlist screening at onboarding, repeated annually for vendors who remain active on the Lumanu network.

Bank detail validation

Bank detail validation

Lumanu validates bank accounts at onboarding for vendors who connect accounts with Plaid. Vendors manage their own payout details in their wallet.

US tax forms

US tax forms

Lumanu collects a W-9 from US vendors before payment. Form status is available on the partner record.

Non-US tax forms

Non-US tax forms

Lumanu collects a W-8 from non-US vendors before payment. Form status is available on the partner record.

TIN matching

TIN matching

A vendor cannot withdraw funds until their TIN matches. Funds can be credited to their wallet but stay locked until then, so a mismatched TIN never triggers backup withholding.

Year-end filing

Year-end filing

Lumanu files 1099s as vendor of record for every vendor it onboards. Your EIN does not appear on those forms.

Payment delivery

Payment delivery

Lumanu delivers payments to the vendor’s bank account, PayPal, or card. If a withdrawal fails, Lumanu resolves it with the vendor.

Vendor support

Vendor support

Lumanu answers vendor questions about onboarding, tax, and payments directly.

What stays with you

  1. Funding. You fund your workspace wallet. Lumanu pays from those funds.

  2. Approval. You decide who gets paid, how much, and when. The API separates creating a payable from approving and paying it. Execution stays with you whether a person or an automated rule manages payment instructions.

  3. Worker classification. You decide whether someone should be engaged as a contractor, and you carry the risk if that decision is challenged. Lumanu pays the vendors you tell it to pay. Lumanu does not determine if a relationship should be classified as contractor or employee or W2 vs W9.

  4. Your agreement with the vendor. Scope, rates, deliverables, usage rights, and termination are between you and the vendor.

What happens at year end

Nothing arrives for you to process. Lumanu files 1099s to the vendors it onboarded, under its own EIN, so you have no forms to issue, no corrections to chase and no vendor queries to field in January.

Your vendor is Lumanu. Lumanu is a registered C corporation and will provide its W-9 and EIN for your accounts payable system. Your AP team uses that W-9 to determine your own reporting position in the normal way, as they would for any corporate supplier.

The impact is you set up and maintain one vendor record instead of a vendor record for each person you pay via Lumanu. 

Evidence and audit

Lumanu does not expose per-vendor screening logs through the API. This is by design. Screening is Lumanu’s obligation, so the screening record is evidence of Lumanu’s own compliance. Your platform does not need it because the obligation is not yours.

If your auditor asks how you know screening happened, point them to two things: the allocation of responsibility in your agreement with Lumanu, and Lumanu’s SOC 2 report. You can also request a summary screening attestation from Lumanu for your paid vendors once per year.

This is the practical difference between partnering with a payout API and partnering with a vendor of record. With a payout API you need the logs, because a regulator with questions about a payment comes to you. With a vendor of record, those questions go to Lumanu.

Lumanu API for integrations or agent-driven workflows

Automated payout flows can be built with logic that requires understanding if a vendor is payable. Lumanu owns compliance and onboarding and provides payable status from a single status field. Your code does not have to include compliance rules or an onboarding state machine.

In order to get payable status you can look up the partner record by Lumanu vendor ID and branch on its status. A vendor waiting on a W-9, a W-8 and the status tells you if this is complete. Your integration does not need to know why a form is required, when it expires, or what a mismatch means. Lumanu manages the onboarding and compliance lifecycle.

Three things to consider when building an integration:

Lumanu supports creating a payable before a vendor finishes onboarding. Lumanu collects the signup and tax form, sends reminders, and releases funds once the vendor completes onboarding. Onboarding does not block the payment, so an automated run can pay for a completed deliverable right away instead of opening a ticket.

The compliance gate is at withdrawal, not payment. A vendor whose TIN has not matched cannot withdraw funds, so money never reaches someone whose tax identity is unverified. You do not need withholding logic for this case because it cannot happen.

Your integration cannot clear compliance states. An agent can detect that a vendor is waiting on a form and flag it. It cannot complete the form, because the form is a signed attestation from the vendor. Treat any non-payable status as an exception to report, not something to work around.

Partner status values are listed under Partners/Vendors in Core Concepts. See Vendor onboarding for the two ways to invite vendors.