AML Policy

Gogojili maintains an anti money laundering and countering the financing of terrorism framework designed to prevent illicit use of its services. This policy governs the identification, verification, monitoring and reporting of customer activity across Gogojili platforms.

Scope and Governance

The policy applies to all customers and all transactions conducted on Gogojili services. The company appoints a designated compliance officer responsible for the AML program, including monitoring, training and escalation procedures. The AML framework is reviewed on a regular basis and updated to reflect changes in law and regulation.

Know Your Customer and Identity Verification

1. Minimum data on onboarding The company collects for each applicant: full legal name, date of birth, nationality, permanent residential address, government issued identification number, and contact details including a valid email address and a phone number.
2. Required documents A government issued identity document such as a passport or national ID, and evidence of address such as a recent utility bill or bank statement showing the applicant’s name and address, dated within the last three months. Where appropriate, additional documents may be requested to resolve uncertainties.
3. Account integrity Anonymous accounts or accounts opened under fictitious names are not allowed. If identity cannot be established or information is inconsistent, the company may suspend or terminate the account and return funds in accordance with internal procedures.

Due Diligence and Ongoing Verification

The company applies a risk based approach to Customer Due Diligence. On onboarding and at ongoing intervals, customer risk is assessed and enhanced due diligence may be performed for higher risk profiles, including politically exposed persons and counterparties with complex ownership structures or high risk transactions. Information and documentation may be updated when risk factors change or new rules apply.

Continuous Transaction Due Diligence and Monitoring

All activity is subject to monitoring for indicators of money laundering or terrorist financing. Key measures include:

• Automatic and manual monitoring of transactions with alerts for unusual patterns or exemptions.
• Transaction review thresholds such as monitoring all transactions above a defined amount and investigating unusual deposit and withdrawal sequences.
• Flow controls to ensure funds are transferred using legitimate and traceable channels and to prevent transfers between unrelated third parties.

When indicators of potential illicit activity are identified, the company will escalate for review by the transaction monitoring team and, if warranted, the Money Laundering Reporting Officer. Findings may be reported to competent authorities in accordance with applicable laws.

Sanctions Screening and Politically Exposed Persons

Customer information is screened against sanctions lists and adverse information sources. If a customer is identified as a politically exposed person, enhanced due diligence is applied and ongoing monitoring intensified. Where risk remains unacceptable, the relationship may be restricted or terminated.

Record Keeping and Data Retention

The company maintains records of customer identities, verification steps, and transactional data for a minimum period as required by applicable law and for the duration of the customer relationship plus an additional retention period. Records include identity documents, proof of address, verification results and transaction histories. Data retention complies with relevant data protection requirements.

Data Privacy and Security

Personal information is processed in accordance with applicable data protection laws. Access to personal data is restricted to authorized personnel and maintained in secure systems with appropriate technical and organizational measures. Cross border transfers are conducted where permitted and under appropriate safeguards. Individuals have rights to access and request correction or deletion of their information as provided by law.

Training and Awareness

All staff receive AML training on a periodic basis, with initial training upon joining and ongoing updates as needed. The MLRO and Transaction Monitoring teams oversee training content and effectiveness, including identification of red flag indicators and escalation procedures.

Prohibited Jurisdictions and Account Actions

The company prohibits onboarding and maintaining customers from jurisdictions where its business activities are restricted or where regulatory requirements cannot be met. In such cases, accounts may be blocked or closed in compliance with applicable laws and internal risk assessments.

Roles and Responsibilities

• Customer: provide accurate information and promptly update details as required.
• Money Laundering Reporting Officer: lead AML program, oversee KYC, monitoring, training and reporting obligations.
• Transaction Monitoring Team: monitor activity, investigate anomalies and escalate to the MLRO when appropriate.

Reporting and Cooperation with Authorities

Suspected money laundering or terrorist financing must be reported in accordance with applicable legal and regulatory requirements. The company cooperates with competent authorities and provides information in a manner consistent with legal obligations and data protection rules.

Policy Review and Updates

This AML policy is reviewed at least annually and whenever regulatory changes necessitate it. Updates are communicated via Gogojili platform notices and become effective on the date specified in the notice.

Contact and Further Information

Customers seeking information or wishing to raise concerns regarding AML compliance should use the standard Gogojili support channels to reach the AML Compliance Unit. All inquiries will be handled in accordance with applicable privacy and data protection requirements.