AML/CTF and KYC Policy

Anti-Money Laundering Policy (Anti-Money Laundering Policy).

The GoldenGate service warns users against attempts to use the service to legalize criminally obtained funds, terrorist financing, illegal actions of any kind, as well as from using the service to purchase prohibited goods and services.

The legalization of funds obtained by criminal means is the concealment of an illegal source of funds by transferring them into funds or investments that look legitimate.

General provisions

To prevent illegal transactions, the Service sets certain requirements for all Applications created by the User:

The sender and the recipient of the Payment on the Application must be the same person. Transfers in favor of third parties are strictly prohibited using the services of the Service.

All contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely reliable.

It is strictly prohibited for a User to create Applications using anonymous proxy servers or any other anonymous Internet connections.

This Anti—Money Laundering Policy (hereinafter referred to as the "AML Policy") describes the procedures and mechanisms used by the GoldenGate Service to counter money laundering, the GoldenGate Service adheres to the following rules:

not to enter into business relations with known criminals and/or terrorists;

do not process transactions that are the result of known criminal and/or terrorist activities;

not to facilitate any transactions related to known criminal and/or terrorist activities;

has the right to restrict or prohibit the use of all or part of the services for citizens of countries such as Afghanistan, Bosnia and Herzegovina, the United States, the Democratic People's Republic of Korea, the Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, the Lao People's Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine.

Verification procedures

The GoldenGate service establishes its own verification procedures within the framework of anti—money laundering standards - the "Know Your Customer" (KYC) policy.

Users of the GoldenGate Service undergo the verification procedure (provide a government identification document: passport or identification card). GoldenGate reserves the right to collect User identification information for the purposes of implementing the AML Policy. This information is processed and stored strictly in accordance with GoldenGate's Privacy Policy and Personal Data Processing Policy.

Also, the GoldenGate Service may request a second document to identify the User: a bank statement or utility bill no older than 3 months, which indicates the User's full name and his actual place of residence, the service also has the right to request photo/video verification of the client, if there is suspicion of dishonesty of the information provided.

The GoldenGate Service verifies the authenticity of documents and information provided by Users, and reserves the right to receive additional information about Users who have been identified as dangerous or suspicious.

If the User's identification information has been changed or his activity has seemed suspicious, then the GoldenGate Service has the right to request updated documents from the User, even if they have been authenticated in the past.

Responsible for compliance with the AML Policy

The person responsible for compliance with the AML Policy is a GoldenGate employee whose responsibilities include ensuring compliance with the AML Policy, namely:

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

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

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

implementation of a records management system for storing and searching documents, files, forms and journals;

regular updating of the risk assessment.

The person responsible for compliance with the AML Policy has the right to interact with law enforcement agencies that are engaged in preventing money laundering, terrorist financing and other illegal activities.

Transaction monitoring

Monitoring User transactions and analyzing the received data is also a tool for risk assessment and detection of suspicious transactions. If money laundering is suspected, the GoldenGate Service monitors all transactions and reserves the right:

report suspicious transactions to the appropriate law enforcement agencies;

ask the User to provide any additional information and documents;

suspend or terminate the User's account.

suspend the exchange and freeze assets until the circumstances are clarified.

to return the funds to the user by canceling the exchange procedure, according to the user agreement

risk assessment

The above list is not exhaustive. The AML Policy Officer monitors User transactions on a daily basis to determine whether they should be reported and treated as suspicious.

In accordance with international requirements, GoldenGate uses a risk-based approach to combat money laundering and terrorist financing. Thus, measures to prevent money laundering and terrorist financing are commensurate with the identified risks

Last updated on 07/04/2024