AML/KYC/SoF Policy

1. General provisions

1.1. This AML/KYC/SoF Policy (hereinafter referred to as the "Policy") sets out the principles and procedures for countering the legalization (laundering) of income and the financing of terrorism, as well as the procedure for verifying clients and transactions on the site. https://goldengatex.net/ru / (hereinafter referred to as the "Service", "GOLDENGATEX").

1.2. The Policy is an integral part of the user the documents of the Service. The User actively agrees with the Policy by means of a mandatory checkbox when creating an Application.

1.3. The Service applies a risk-based approach and has the right to suspend the execution of Applications and request supporting materials for the purposes of AML/KYC/SoF and transaction security.

1.4. The Service does not mine digital currency, does not organize mining pools, and is not an operator of the mining infrastructure.

2. Terms and definitions

2.1. AML verification – analysis of the address/TxID/transaction/chain of transactions in order to assess risks.

2.2. AML analyzer is a software product/service used for AML checks and risk-Score formation.

2.3. Risk-Score is a risk assessment (in the form of a score/percentage / category), including the classification of Low / Medium / High (or the equivalent scale of the analyzer).

2.4. AML-Hold – temporary suspension of Application execution until completion of verification and/or submission of documents.

2.5. KYC – verification of the User's identity.

2.6. SoF – confirmation of the Source of funds.

3. AML control tools

3.1. For AML checks, the Service uses an AML analyzer(s) determined by the Service Administrator, including BitOK and other valid blockchain transaction analysis tools. In some cases, external AML reporting services may be used for the purpose of preliminary user verification or additional risk assessment.

3.2. The results of the AML analyzer are used for:

3.2.1. making a decision on the execution/suspension/refusal of the Application;

3.2.2. determining the need for KYC/SoF;

3.2.3. quality control of assets provided to the User as part of the execution of Requests (incoming/outgoing transactions).

3.3. Preliminary AML verification of the User's digital currency address can be carried out before issuing the details as part of the Application. If a high level of risk, critical tags, or other significant AML risks are identified, the Service has the right to refuse to process the Application and ask the User to specify a different address.

4. Risk-Score model and thresholds

4.1. The Service applies a risk assessment model in which each transaction/address is assigned a Low/Medium/High risk level and/or a numerical score.

4.2. The AML-Hold threshold.

The AML-Hold is applied when any of the following conditions are met:

a) the risk level is High; or

b) risk-Medium level in the presence of critical labels (sanctions/terrorism/ransom/mixer/darknet/scam/stolen, etc.); or

c) Risk-Score ≥ 60 (on the analyzer scale) or another threshold set by the Administrator and published in the current version of the Policy.

4.3. The Service has the right to apply additional AML-Hold triggers when detecting abnormal patterns, discrepancies in banking details, signs of social engineering/fraud, as well as if there are matches on the official lists.

5. KYC/SoF procedures

5.1. Depending on the level of risk, the Service may request one or more materials.:

5.1.1. identity document (passport/ID), a selfie with the document;

5.1.2. address confirmation;

5.1.3. Confirmation of the source of funds (SoF): statement/certificate/transaction history/explanation of the origin of funds/other confirmations;

5.1.4. proof of ownership of payment details (card/account/ SBP): photos, screenshots, other confirmations, and if there are significant risks, a photo of the bank card against the background of the Service page and/or other materials that allow to confirm the ownership of the details to the User.;

5.1.5. confirmation of the fact of payment/crediting: TxID, PDF receipt, statement, screenshots, video recording of the transaction history or current account status, if necessary (including to exclude the disputed crediting).

5.2. The Service has the right to refuse service if:

5.2.1. refusal to provide materials;

5.2.2. providing deliberately false information;

5.2.3. providing materials with signs of forgery/editing.

6. Verification stages and estimated deadlines

6.1. A preliminary AML check is performed before issuing the Application details and/or at other stages of processing the transaction, including checking the User's digital currency address, TxID, and other data relevant to the risk assessment.

6.2. During AML-Hold, the Service requests KYC/SoF materials and/or transaction confirmation.

6.3. Approximate dates:

6.3.1. standard check: up to 24 hours;

6.3.2. extended verification: up to 7 calendar days;

6.3.3. The time limits may be extended if the User delays the provision of materials or if additional data verification is required.

6.4. Before submitting the requested materials, the execution of the Application may be suspended without recognizing a violation of the processing time.

7. Decisions based on the results of the audit

7.1. Based on the results of AML/KYC/SoF, the Service makes one of the following decisions:

a) execute the Application;

b) suggest that the User replace the digital currency address and/or other banking details if the risk is associated with a specific address, wallet, transaction, or transfer method used.;

c) refuse to comply and initiate a refund in accordance with Section 8 (if the refund is applicable within the framework of the settlement model and if the refund details are confirmed).

7.2. The Service has the right to request additional materials if the information originally provided is insufficient.

8. Terms and conditions of return for AML cases. Commissions

8.1. Refunds are made only to banking details / addresses, the ownership of which has been confirmed by the User and which have been checked by the Service for the admissibility of the refund from the point of view of AML / security.

8.2. The refund fee/deduction may not exceed the actual cost of the refund, and is additionally limited to: up to 5% of the refund amount, but not more than USD 100 in equivalent at the time of the refund, plus the actual network commission.

8.3. For bona fide Users, whose KYC/SoF results have not confirmed the connection of funds with illegal sources, deductions are limited solely to the actual network commission (without additional interest).

8.4. Estimated refund period after making a decision and receiving the correct details/ address: up to 3 business days, unless otherwise stipulated by the work of the bank/ payment system/ blockchain network or the need for additional verification of the refund details.

9. “Purity” of incoming and outgoing transactions and address policy

9.1. The Service takes reasonable measures to ensure the quality and legitimacy of assets transferred to Users, and conducts AML verification of incoming and outgoing transactions, as well as applies an internal address policy regarding operational wallets, acceptance addresses, consolidation addresses, and payment sources.

9.2. The Service does not allow assets from high-risk sources to be sent to the User, and also has the right to replace the source/payment route to reduce risks.

9.3. To exclude the issuance of high-risk assets to Users, the Service uses one or more of the following approaches:

(a) accepting digital currency to operational addresses, including dynamic and/or unique addresses used for specific Applications;

(b) the subsequent consolidation of the received assets within the internal infrastructure of the Service;

(c) using the exchange infrastructure of proven platforms as a source of outgoing transactions to Users;

(d) in some cases, the use of transit addresses previously replenished from the exchange infrastructure, subject to internal control of the origin of assets and the absence of critical AML tags at the source of funds;

(e) maintaining internal accounting and control of addresses used in operational activities, without mandatory public disclosure of the full structure of the address infrastructure.

9.4. At the request of the monitoring organizers, partners, or as part of verification, the Service may provide supporting materials on the applied address model and sources of operations, including screenshots of AML analyzer reports, TxID, description of the architecture of funds movement, and other information that does not disclose Users' personal data and does not create unjustified risks to the security of the Service infrastructure.

9.5. The Service has the right not to publish or publicly disclose the full structure of its operational addresses if such disclosure may create increased security risks, infrastructure blockages, restrictions from counterparties or other significant operational risks, provided that asset quality requirements are met and the necessary confirmation is provided as part of the audit.

10. Responsible for compliance with the AML Policy

The AML Policy Compliance Officer is a GOLDENGATEX employee whose responsibilities include ensuring compliance with the AML Policy, namely:

10.1 Collecting User identification information and transferring it to the responsible personal data processing agent;

10.2 Create and update internal policies and procedures for writing, reviewing, submitting, and storing all reports required by existing laws and regulations;

10.3 monitoring of transactions and analysis of any significant deviations from normal User activity;

10.4 implementation of a record management system for storing and searching documents, files, forms and logs;

10.5 regular updating of the risk assessment.

10.6 The AML Policy Officer has the right to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.

11. Data processing and consent recording