The Anti-Money Laundering, Countering Financing of Terrorism and Know Your Customer Policy (hereinafter - the "AML/CFT Policy") of Gocommex is designated to prevent and mitigate possible risks of Gocommex being involved in any kind of illegal activity.
the conversion or transfer of property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s actions;
the acquisition, possession or use of property derived from criminal activity or property obtained instead of such property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation therein;
the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such an activity.
Money laundering also means participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the activities referred to above.
Terrorist financing is defined as the financing and supporting of an act of terrorism and commissioning thereof as well as the financing and supporting of travel for the purpose of terrorism.
Both international and local laws and regulations require Gocommex to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
internal controls;
compliance officer;
training of personnel;
verification procedures;
monitoring, risk assessment and risk-based approach;
AML/CFT program audit.
We have designed a structured system of internal controls in order to comply with applicable Anti-Money Laundering, Countering Financing of Terrorism (AML/CFT) laws and regulations, including, but not limited to:
establishing customer's identity and verifying the information provided;
establishing a special regime for dealing with customers who are politically exposed persons (PEP);
the identification of unusual activity and facilitating the reporting of suspicious activity (SAR);
record keeping of customer documentation and transactional history.
The Compliance Officer is the person, duly authorized by Gocommex, responsible for developing and enforcing effective AML/CFT implementation. The Officer must report any violations and collect and file SARs.
The Compliance Officer’s responsibilities include:
establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under applicable laws and regulations;
collecting users’ identification information and verifying it; implementing a records management system for proper storage and retrieval of documents, files, forms and logs;
collecting and analyzing information related to unusual or suspicious transactions and circumstances; investigating any such activity;
reporting suspicions of money laundering or terrorist financing to appropriate authorities; providing law enforcement with required information;
periodically submitting written compliance statements to the management board;
organizing employee training;
performing other duties related to legal compliance; regularly updating the risk assessment.
The Compliance Officer is entitled to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.
All employees receive full AML/CFT training, along with job‐specific guidance. Training is conducted at least once every twelve (12) months to ensure compliance with all applicable laws and regulations. Employees undergo additional training if new laws or regulations are adopted or as required by law. New employees receive relevant training before starting work. The training program is regularly updated to reflect current laws and regulations.
Gocommex establishes its own customer verification procedures within AML/CFT frameworks.
Gocommex carries out due diligence and KYC checks before entering business relations with a customer or contractor;
In the KYC process and account opening, the person’s identity, provided information, and submitted documents are verified and checked against sanctions and watch lists, including the PEP list; Gocommex uses special tools and a structured verification system for this;
For legal entities (their owners/shareholders/beneficiaries, etc.), Gocommex performs enhanced due diligence, KYC, and compliance procedures;
Gocommex ensures specific enhanced identification, KYC, due diligence, and compliance procedures for customers designated as PEP, regardless of their place of residence.
The Compliance Officer conducts investigations for incoming and outgoing transactions based on various factors, including an automated transaction verification system, with verification periods of up to 24 hours. Gocommex carries out customer transaction monitoring, risk assessment and suspicious activity detection using a specially developed high-performance system.
Gocommex uses a risk-based approach to combating/preventing money laundering and/or terrorist financing.
To determine the level of AML/CFT due diligence, a compliance risk profile (Low, Medium, High) is calculated upon onboarding and then routinely recalculated.
AML/CFT compliance ensures ongoing transaction monitoring to detect transactions unusual or suspicious compared to the customer profile.
Determination of unusual transactions depends on subjective assessment relative to customer knowledge (KYC), their financial behavior, and counterparty.
If a transaction is inconsistent with a customer’s known activities or habits, it may be considered suspicious. Data and transaction monitoring tools identify such patterns. After review, the Compliance Officer decides whether to file a SAR.
Once a SAR is filed, a copy of the filing documentation is maintained confidentially, known only to those Gocommex employees involved in the investigation and reporting process.
All records are retained for no less than five (5) years and are available upon official request by an authorized examiner, regulator, or law enforcement agency.
Any Gocommex staff member must inform the Compliance Officer of any atypical transactions that cannot be attributed to lawful activity or a known source of customer income.
The Compliance Officer is responsible for conducting AML/CFT audits at least annually. Other audit requirements are defined in internal policies and procedures.
upon establishment of a business relationship;
upon verification of information gathered during due diligence or if there are doubts about the sufficiency or truthfulness of previously collected documents or data when updating relevant information;
upon suspicion of money laundering or terrorist financing;
in other cases, including those prescribed by law and when “red flags” are identified according to internal procedures.
We retain originals or copies of documents used for identification and verification of persons, and documents establishing a business relationship, for no less than five years after termination of that relationship.
We retain documents prepared for a transaction on any data medium, and documents and data forming the basis for reporting obligations, for no less than five years after the transaction or the reporting duty is fulfilled.
checking of transactions made in a business relationship in order to ensure that the transactions are in concert with our knowledge of the customer, its activities and risk profile;
regular updating of relevant documents, data or information gathered in the course of application of due diligence measures;
identifying the source and origin of the funds used in a transaction;
paying more attention to transactions that are likely to be linked with money laundering or terrorist financing, including complex, high-value and unusual transactions and transaction patterns that do not have a reasonable or visible economic or lawful purpose or that are not characteristic of the given business specifics;
paying more attention to the business relationship or transaction whereby the customer (or payment provider, etc. of the customer) is from a high-risk third country or a country or territory specified by law as a country or jurisdiction with factor(s) increasing the geographical risk.