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AML Policy

Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy

The Gatecoin AML/CFT Policy is designed to ensure that all Group Companies comply with the requirements and obligations set out in Hong Kong and international legislations, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by all Gatecoin Companies and employees and includes:

  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the Group;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking relationships;
  • Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • Procedures for reporting suspicious fraudulent use of identification documents to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employees;
  • And the provision of appropriate management information and reporting to senior management of the Group's compliance with the requirements.
  • Gatecoin may require its clients to provide additional information or documentation to fulfil our legal obligations and where it deems appropriate refuse any client or transaction that is suspected of being related to financial crime.

The appointment of a Group Money Laundering Reporting Officer (GMLRO) and Business Unit Money Laundering Reporting Officers (MLROs) of sufficient seniority, who have responsibility for oversight of Group and Business Unit compliance with relevant legislation, regulations, rules and industry guidance;