AML CTF Policy

1. INTRODUCTION
The Gilcoin AML Policy is designed to prevent money laundering by meeting the Polish and European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.

It is prohibited to provide any product or service or process any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing, in particular the EU and UK Anti-Money Laundering Act, (hereinafter referred to as “AML”) is mandatory and fundamental to Gilcoin’s strategy and program.

Gilcoin has strict and transparent standards and continuously strengthens its processes so as to ensure compliance with applicable AML laws and regulations.

Gilcoin reserves the right to reject any customer, payment or business that is not consistent with the Gilcoin AML policy, irrespective of the requirements of the applicable AML laws and regulations.

2. MAIN OBJECTIVES

• Combating and preventing money laundering and terrorist financing and taking all the necessary preventive measures;
• Preventing the misuse of the Company by anyone or anybody in illegitimate operations;
• Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules and industry guidance;
• Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
• Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
• Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
• Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities, such as the Money Laundering Reporting Office Switzerland (MROS), as appropriate;
• Maintaining appropriate records for the minimum prescribed periods;
• Training all employees on the rules and internal procedures which have to be observed, the risks that they and the Company face and how they can encounter the risks of money laundering and terrorist financing through their operations from their positions.

3. COMPANY COMMITMENT
Gilcoin is committed to:

• Accept only those Customers whose identity can be established and verified and whose source of funds can be reasonably established to be legitimate;
• Not establish a business relationship, open accounts or maintain accounts for anonymous persons or those with fictitious names including anonymous accounts;
• Make every possible effort to know the identity of the customer and the real beneficiary (Beneficiary Owner) of the account (i.e. the full name, the place and date of birth and verifying the identity by using valid, official and accredited documents “identification data” issued by the official bodies), in addition to the data and information available from trusted independent sources;
• Apply a risk-based approach, and enhanced customer due diligence where required;
• Monitor and identify suspicious transactions and activities and ensure that reportable ones get reported;
• Provide regular and appropriate AML / CTF training and information to all employees to increase their awareness using various methods;
• Maintain records, which are appropriate to the nature and complexity of the customer’s business.

4. CUSTOMER DUE DILIGENCE
In terms of its obligations at law, Gilcoin is obliged to determine the applicant for business, the Customer or any beneficial owner, and to verify that such person is the person he purports to be, as well as to determine whether such person is acting on behalf of someone else, and to establish the purpose and intended nature of the business relationship and to monitor this relationship on an ongoing basis. In order to successfully adhere to its obligations, Gilcoin has developed Customer due diligence (“Due Diligence”) measures which must be implemented by Gilcoin and adhered to by its management and employees.

The Due Diligence measures assist Gilcoin in determining whether a particular Customer falls within their risk appetite, as well as helps the Company clearly understand the business activities of the Customer in such a way that any transactions which fall outside the business profile of the company may be investigated to determine whether any money laundering or funding of terrorism may be involved. This enables the Company to inform relevant authorities in a timely manner with adequate information on its Customer and their activities when such a request is made.

• In summary, Gilcoin has adopted its Due Diligence policies in order to successfully carry out the following:
  identification and verification of the applicant for business
• identification and verification of the beneficial owner, where applicable
• identification and verification when the applicant for business does not act as principal
• obtaining information on the purpose and intended nature of the business relationship
• conducting ongoing monitoring of the business relationship
• establishing the source of wealth and source of funds
• setting up of a Customer acceptance policy and ensuring that the applicant for business meets the requirements set out in such policy
  Gilcoin is strictly prohibited from keeping anonymous accounts or accounts in fictitious names.

4.1. Prohibitions
Gilcoin has no AML risk appetite for customers who engage in any of the following activities:

• intentional or willfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;
• repeated unintentional or repeated accidental breaches of AML laws;
• misusing the account for the purpose of money laundering or terrorism financing;
• misusing the account for the purpose of other fraud;
• facilitating business activities which could be construed as a tax offence;
• refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in Gilcoin AML policy.

The Company has no risk appetite for customers or transaction to or from jurisdictions which are identified as high-risk third countries on the lists of jurisdictions having serious deficiencies in their anti-money laundering regimes drawn up by the European Commission and the FATF and as amended from time to time, including but not limited, onboarding clients from or executing transaction to or from: Afghanistan, Belarus, Burundi, Central African Republic, Crimea, Cuba, Democratic Republic of Congo, Guinea, Guinea-Bissau, Iran, Iraq, Libya, Myanmar, Nicaragua, North Korea, Republic of Mali, Sevastopol, Somalia, South Sudan, Sudan, Syria, USA (incl. US territories), Venezuela, Zimbabwe.

Gilcoin intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. In keeping with that principle, the Company will not knowingly conduct business with customers that seek to process payments through the Company involving:

• Collecting donations as a charity or non-profit organization, NGO’s (unregulated and incorporated outside EU/Switzerland);
• Dating (newly incorporated, not known);
• Drug paraphernalia – product or accessory that is intended or modified for making, using, or concealing drugs, typically for recreational purposes;
• Drugs / Illicit substances, steroids and certain controlled substances or other products that present a risk to consumer safety;
• Extractive Industries;
• High Risk File hosting / sharing and cyberlockers;
• Infringe any duly registered copyrights/trademarks or other violation of intellectual property rights;
• Unregulated pharmaceuticals, illegal drugs and or unlicensed drug related activity;
• Involve offering or receiving payments for the purpose of bribery or corruption or any form of high yield financial investments (get rich quick schemes);
• Items that encourage, promote, facilitate or instruct others to engage in illegal activity;
• PC Support sold via outbound telemarketing;
• Pyramid or Ponzi schemes;
• Relate to the sale of dangerous or hazardous goods;
• Replicas;
• Sale of government ID’s or documents;
• Scottish LP, LLP;
• Services associated with prostitution, escort;
• Stolen goods including digital and virtual goods (fictitious social media likes, spam emails);
• Unlicensed lottery and gambling;
• Unregulated crypto companies (except EU/Switzerland);
• Unregulated Forex;
• Violate any law, statute, ordinance or regulation;
• Weapons, firearms and ammunitions;

Please note that the company may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

4.2. Sanctions
Gilcoin has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation:

• the Swiss Federal Council Sanctions List;
• the United Nations Security Council Sanctions List (UN);
• the Consolidated List of European Union Financial Sanctions (EU);
• sanction lists administered by the United States Office of Foreign Assets Control (OFAC),
• including the List of Specially Designated Nationals and Blocked Persons;
• any other sanctions list.

In addition, Gilcoin pays particular attention to entities from countries which are on the list of noncooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

5. MONITORING FOR SUSPICIOUS ACTIVITY
Gilcoin AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, Gilcoin may request information regarding the transactions carried out through the customer’s account opened at Gilcoin and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, Gilcoin also reserves the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.