Anti-Money Laundering Practices, Procedures and Controls

  1. Introduction
  2. Anti-Money Laundering Policy
  3. Client Identification
  4. Client Due Diligence
  5. Record-keeping of identification and due diligence
  6. Limitations on anonymous activities
  7. Client activity monitoring to detect suspicious activity
  8. Steps to be taken when suspicious activity is detected
  9. Audit process to test controls
  10. Watch list and Compliance with U.S. sanctions programs
  11. OFAC compliance
  12. Periodic independent audit of GCB Suisse AML system

 

1. Introduction

GoldenSuisse maintains Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) policies, as set out by FINMA, in regards to verifying the identity of its clients and assessing potential risks of illegal intentions for the business relationship.

Every account holder goes through an on-boarding process that includes a background check and mobile phone verification. We implement these policies not to preclude anyone from the service, but to strengthen the integrity of our company for all stakeholders.

The aforementioned AML Policies, Procedures and Controls of GoldenSuisse:

  • Set out clearly the company’s policies and principles set up by board of directors and shareholders of the company, and for management to uphold
  • Contribute towards a better understanding of corporate decisions by our employees
  • Aim to motivate staff to achieve the maximum possible potential for all stakeholders

These Policies, Procedures and Controls are required to be implemented by all staff members at every level of the company on a day – to – day basis.

This document brings together individual company Policies, Procedures and Controls into one document that sets out the standards expected of shareholders, senior management, employees, service providers, clients, and suppliers, and provide a code of ethical and professional conduct for everyone to follow.

 

2. Anti-Money Laundering Policy

It is the policy of the Company to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorism or criminal activities. All employees of the company are required to commit to maintaining the highest possible ethical standards of business conduct and adhere strictly to the Company’s AML and KYC Compliance policies and procedures.

 

Money Laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived income so that the unlawful proceeds appear to have derived from legitimate origins or constitute authentic assets.

 

3. Client Identification

The purpose of Client Identification is to:

  • Mitigate risk from online fraud (identity and age verification)
  • Regulatory compliance with regional and international Anti-Money Laundering regulations

 

The client is identified by the company during the sign-up and on-boarding process in the mobile app, and in order to be eligible to become a GCB Group Client the following information must be provided.

  1. Valid Passport copy
  2. Proof of Address
  3. Personal Bank Statement
  4. Email address
  5. Mobile Phone Number

 

4. Client Due Diligence

All eligible Clients are subject to a Due Diligence process, both during the sign-up process as well as afterwards during the business relationship.

 

All Client personal data as well as documents is verified by GCB’s against updated watchlists as required by current AML legislation.

 

5. Record Keeping of Identification

All Client Identification and Due Diligence records are kept encrypted. Backups of all client data and transactions will be kept for the time required by law.

 

6. Limitations on anonymous activities

Clients who’s activities cannot be verified are to be considered anonymous, and their average gold coin holdings shall be limited.

 

Any funds arriving from other source than the clients personal verified bank account will not be accepted.

 

7. Client activity monitoring to detect suspicious activity

All staff must raise an internal report where they have knowledge or suspicion, or where there are reasonable grounds for having knowledge or suspicion, that another person is engaged in money laundering, or that terrorist property exists.

 

8. Steps to be taken when suspicious activity is detected

GCB Group nominated officer (or their appointed alternate) must consider all internal reports regarding suspicious activity.

 

GCB Group nominated officer (or their appointed alternate) must make an external report to the National Crime Agency (NCA) as soon as is practicable if he considers that there is knowledge, suspicion, or reasonable grounds for knowledge or suspicion, that another person is engaged in money laundering, or that terrorist property exists.

 

GCB Group must seek consent from the NCA before proceeding with a suspicious transaction or entering into arrangements.

 

GCB Group nominated officer (or their appointed alternate) must make an external report to the National Crime Agency (NCA) as soon as is practicable if he considers that there is knowledge, suspicion, or reasonable grounds for knowledge or suspicion, that another person is engaged in money laundering, or that terrorist property exists.

 

GCB Group must freeze funds if a customer is identified as being on the Consolidated List on the FINMA website of suspected terrorists or sanctioned individuals and entities, and make an external report to FINMA.

 

It is a criminal offence for anyone, following a disclosure to a nominated officer, to do or say anything that might either ‘tip off’ another person that a disclosure has been made or prejudice an investigation.

 

GCB Group nominated officer (or their appointed alternate) must report suspicious approaches, even if no transaction takes place

 

9. Audit process to test controls

GCB Suisse’s Anti-Money Laundering Policies, Procedures and Controls are supervised yearly by Swiss independent auditors approved by the Swiss Financial Authority FINMA.

 

10. Compliance with U.S. sanctions programs

  1. Each GCB Suisse Client is checked against the Specially Designated Nationals and Blocked Persons List (the “SDN List”) issued by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), at the time the relationship is established and on an ongoing basis. Any Activity with a person or entity found to be on the SDN List is immediately terminated; and
  2. No Activity is conducted in a country subject to OFAC sanctions programs.