GHF Coin's Anti-Money Laundering Policy

Dear Global GHF Coin Users,

Please carefully review the GHF Coin Anti-Money Laundering (AML) and Know Your Customer (KYC) policies.

GHF Coin AML/KYC Policy and Procedures

This policy pertains to GHF Coin’s AML and counter-terrorism financing (AML/KYC) policies and procedures. It is intended solely for general informational purposes and does not carry any legal binding force on GHF Coin and/or any other person (natural or legal).

A. Principles and Methods of GHF Coin's AML/KYC Operations

GHF Coin is committed to supporting AML/KYC operations. In principle, we strive to:

• Conduct due diligence when dealing with our clients or natural persons acting on behalf of our clients;
• Develop business according to high ethical standards and prevent establishing any business relationships that are related to or may assist money laundering or terrorism financing;
• Assist and cooperate with relevant legal authorities to prevent the threats of money laundering and terrorism financing to the fullest extent possible.

B. GHF Coin's Risk Assessment and Mitigation Methods

Risk Assessment

We anticipate that the majority of our clients are retail clients, and as of the date of this policy, we will primarily operate in the Republic of Seychelles.

In this regard, we will:

a. Record and/or collect documents related to:

1. The identity of our clients;
2. The country or jurisdiction from which our clients come or where they are located;

b. Ensure, to the best of our knowledge, skills, and ability, that we assess and screen our clients, their associates, natural persons appointed to act on behalf of clients, and beneficial owners of clients against designated individual and entity lists, including but not limited to:

• Democratic People’s Republic of Korea;
• Democratic Republic of the Congo;
• Iran;
• Libya;
• Syria;
• South Sudan;
• Sudan;
• Yemen;
• UN1267/1989 Al-Qaida List;
• UN1988 Taliban List;
• Individuals identified in the Terrorism (Sanctions) Act (Chapter 325) Schedule 1.

Risk Mitigation

If identified, we will not engage with any individual or entity on the sanctioned list.

C. Our New Products, Practices, and Technological Methods

We will provide appropriate advice on identifying and assessing money laundering and terrorism financing risks in relation to:

• Development of new products and business practices, including new delivery mechanisms;
• Use of new or developing technologies for new and existing products.

We will pay special attention to any new products and business practices, including new delivery mechanisms and new or developing technologies, that facilitate anonymity, such as digital tokens (whether securities, payment, or utility tokens).

D. Our Customer Due Diligence (CDD) Methods

We do not open, maintain, or accept anonymous or pseudonymous accounts.

If we have any reasonable grounds to suspect that a client’s assets or funds are derived from drug trafficking or criminal activities, we will not establish a business relationship or conduct transactions for that client. We will submit a suspicious transaction report for such transactions and provide a copy to the relevant financial intelligence units.

We will perform customer due diligence in the following cases:

• When establishing a business relationship with any client;
• When conducting transactions for any client not having an established business relationship with us;
• When receiving cryptocurrency through transfers for clients with whom we do not have a business relationship;
• When suspicions arise about money laundering or terrorism financing;
• When doubts exist regarding the authenticity or adequacy of any information.

When we suspect that two or more transactions are or may be related, connected, or deliberately restructured into smaller transactions to avoid AML and counter-terrorism financing measures, we will treat the transactions as a single transaction and aggregate their value to comply with AML and counter-terrorism financing principles.

Customer Verification

We will perform verification for each of our clients.

To verify our clients, we must know at least:

• Their full name, including any aliases;
• Their unique identification number (e.g., ID number, birth certificate number, passport number, or, if the client is not a natural person, their business registration number);
• Their registered address, or their registered business address (if applicable). If the registered address and business address differ, choose their primary business location;
• Their date of birth, establishment, or registration;
• Their nationality or place of registration.

If the client is a legal entity, in addition to obtaining the above information, we must determine its legal form, articles of association, and the powers that govern and constrain the entity; we will also identify its associates (e.g., directors, partners, and/or persons with executive authority) by obtaining at least the following information for each associate:

• Full name, including any aliases;
• Unique identification number, such as the associate's ID number, birth certificate number, or passport number.

Verification of Client Identity

We will use reliable, independent source data, documents, or information to verify the identity of our clients. If our client is a legal entity or legal arrangement, we will use reliable, independent source data, documents, or information to verify the legal form, existence, articles of association, and the powers governing the client.

Identification and Verification of Natural Persons Designated to Act

a. Client Representatives

If a client designates one or more natural persons to act on their behalf or if the client is not a natural person, we will:

• Identify each natural person designated to act or appointed to act on behalf of the client by obtaining:
  • Their full name;
  • Their unique identification number;
  • Their address;
  • Their date of birth;
  • Their nationality;
  • Verification of the above natural person's identity using reliable, independent source data, documents.

We will also verify the appropriate authority of each natural person designated to act on behalf of the client by obtaining:

• Appropriate written evidence authorizing the client to designate such a person;
• Signature samples of each natural person.

If the client is a government entity, we will only obtain the information necessary to confirm that the client is the government entity it claims to be.

Identification and Verification of Beneficial Owners

We will inquire whether there are beneficial owners related to the client.

If the client has one or more beneficial owners, we will identify the beneficial owners and take reasonable measures to verify their identity using information or data obtained from reliable, independent sources. We should:

If the client is a legal entity:

• Identify the natural persons who ultimately own the legal entity (whether acting alone or jointly);
• If there is doubt about whether the natural persons ultimately owning the legal entity are beneficial owners or if no natural person ultimately owns the legal entity, identify the natural persons who ultimately control or have effective control of the legal entity (if applicable); and
• If no natural person is identified, determine the natural persons with executive authority in such a legal entity.

If the client is a legal arrangement:

• For trusts, identify the settlor, trustee, protector (if applicable), beneficiaries, and any natural persons who exercise ultimate ownership, control, or effective control of the trust; and
• For other types of legal arrangements, identify personnel in equivalent positions.

If our client is not a natural person, we will determine the nature, ownership, and control structure of the client's business.

If there are beneficial owners of the client, we will be required to confirm their identity:

• For entities listed on stock exchanges;
• For stock exchange-listed entities subject to regulatory disclosure requirements and transparency requirements concerning their beneficial owners;
• For financial institutions;
• For financial institutions that comply with and supervise AML/CFT requirements meeting FATF standards; or
• For financial instruments managed by financial institutions or subject to AML/CFT requirements consistent with FATF standards.

Unless we suspect the authenticity of CDD information or believe that the client's business relationship or transactions might be related to money laundering or terrorism financing.

We will also record the basis for our determinations.

Information on the Purpose and Expected Nature of Unopened Account Business Relationships and Transactions

When processing applications to establish a business relationship or engage in non-public transactions, we should understand and, as appropriate, obtain information from the client about the purpose and expected nature of the business relationship or transaction.

Review of Transactions Without an Established Account

If we conduct one or more transactions for a client without establishing an account (current transactions), we will review the client’s previous transactions to ensure that the current transaction aligns with our understanding of the client, their business, risk profile, and source of funds.

When establishing a business relationship with a client, payment service providers should review all transactions before establishing the relationship to ensure the business relationship aligns with our understanding of the client, their business, risk profile, and source of funds.

We will pay particular attention to all complex, unusually large, or unusual transaction patterns without an established account that have no apparent economic purpose. We will investigate the background and purpose of such transactions as far as possible and document the findings to provide to relevant authorities if needed.

To review transactions without an established account, we will establish and implement appropriate systems and processes commensurate with the scale and complexity of the payment service provider to:

• Monitor transactions conducted without opening an account;
• Detect and report suspicious, complex, unusually large, or unusual transaction patterns conducted without an account.

If there are reasonable grounds to suspect that transactions conducted without an account are related to money laundering or terrorism financing, and if we consider it appropriate to proceed with the transactions, the payment service provider should confirm and document the reasons for conducting the transactions.

Ongoing Monitoring

We will continuously monitor business relationships with clients. During the business relationship, we will observe the client’s account operations and review transactions throughout the business relationship to ensure they align with our understanding of the client, their business, risk profile, and source of funds as appropriate.

If transactions involve transferring cryptocurrency to or receiving cryptocurrency from the following entities, we will implement our risk mitigation measures:

• Financial institutions; or
• Financial institutions complying with and supervised according to FATF standards for AML/CFT requirements.

We will pay particular attention to all complex, unusually large, or unusual transaction patterns throughout the business relationship that have no apparent economic or legal purpose. We will investigate the background and purpose of such transactions as far as possible and document the findings to provide to relevant authorities if needed. For ongoing monitoring, we will establish and implement appropriate systems and processes commensurate with the scale and complexity of the payment service provider to:

• Monitor the business relationship with the client; and
• Detect and report suspicious, complex, unusually large, or unusual transaction patterns throughout the business relationship.

We will ensure that the CDD data, documents, and information obtained for the client, designated representatives, client associates, and beneficial owners remain relevant and up-to-date by reviewing existing CDD data, documents, and information, particularly for higher-risk client categories.

If there are reasonable grounds to suspect that an existing business relationship with the client is related to money laundering or terrorism financing, and if we consider it appropriate to retain the client:

• We will confirm and record the reasons for retaining the client; and
• Appropriate risk mitigation measures should be applied, including enhanced ongoing monitoring.

When we assess that a client or business relationship poses a higher risk, payment service providers should implement enhanced CDD measures, including obtaining approval from senior management to retain the client.

Non-Face-to-Face Business Relationship or Non-Face-to-Face Transaction CDD Measures

We will establish policies and procedures to address any specific risks associated with non-face-to-face business relationships or non-face-to-face transactions (non-face-to-face business contacts).

We will implement these policies and procedures when establishing business relationships and conducting ongoing due diligence.

If there is no face-to-face contact, payment service providers should implement CDD measures at least as stringent as those required for face-to-face contact.

When payment service providers conduct initial non-face-to-face business contacts, they should engage an external auditor or independent qualified consultant to assess the effectiveness of the policies and procedures, including any technological solutions for managing impersonation risks.

We will appoint an external auditor or independent qualified consultant to assess new policies and procedures and submit the assessment report to the management within one year of implementing policy and procedure changes.

Acquisition of Payment Service Providers' Dependence on Existing Measures

When we (the acquiring payment service provider) fully or partially acquire another payment service provider’s business, we will review the client measures obtained through that business at the time of acquisition, unless the acquiring payment service provider:

• Obtains all corresponding client records (including CDD information) and has no doubts or concerns about the accuracy or adequacy of the information obtained; and
• Conducts due diligence and raises no concerns about the adequacy of the AML/CFT measures taken by the acquired payment service provider for the business or part of the business now acquired, and documents such processes.

Measures for Non-Account Holders

If we conduct transactions for any client with whom we do not have other business relationships, we will:

• Implement CDD measures as if the client had applied to establish a business relationship with the payment service provider; and
• Record detailed information about the transaction to reconstruct it, including the nature and date of the transaction, the type and amount of currency involved, the value date, and the details of the payee or beneficiary.

Timing of Verification

We will complete the verification of the client's, the designated representatives' identity, and the client's beneficial owners before the following situations occur:

● Payment service providers establish business relationships with customers;

● Payment service providers conduct transactions for customers before the customer has established a business relationship with the payment service provider;

● Payment service providers facilitate or receive digital payment tokens for customers through value transfers, where the customer has not yet established a business relationship with the payment service provider.

In the following cases, our providers may establish a business relationship with the customer before completing identity verification of the customer, the natural person designated to act on behalf of the customer, and the beneficial owner of the customer:

● Delaying verification is crucial to avoid disrupting normal business operations;

● The risk of money laundering and terrorist financing can be effectively managed through payment services.

If we establish a business relationship with the customer before verifying the identity of the customer, the natural person acting on behalf of the customer, and the beneficial owner of the customer, we should take the following measures:

● Develop and implement internal risk management policies and procedures that specify the conditions for establishing such business relationships before verifying identities.

● Complete identity verification as soon as reasonably possible.

If the measures are not completed:

If we are unable to complete the measures as required, we will not start or continue a business relationship with any customer or execute any transaction for any customer.

If we are unable to complete these measures, the payment service provider should consider whether the situation is suspicious and whether it is necessary to submit a suspicious transaction report.

Completing the measures means that the payment service provider has obtained, screened, and verified (including delayed verification as described in paragraphs 6.43 and 6.44) all necessary customer identification information as outlined in paragraphs 6, 7, and 8, and has received satisfactory responses to all inquiries related to this necessary customer identification information.

Joint Accounts

For joint accounts, we will treat each joint account holder as an individual customer of the payment service provider and apply customer due diligence measures to each.

Screening: We should screen the customer, the natural person designated to act on behalf of the customer, the customer's related parties, and the customer's beneficial owners against information sources related to money laundering and terrorist financing, as well as lists and information provided by authorities to determine if the customer poses any money laundering or terrorist financing risk.

We will screen in the following situations and for the following individuals:

● When we establish a business relationship with the customer (or as soon as reasonably practicable after establishing the relationship).

● Before executing any transaction for a customer who does not have a business relationship with the payment service provider.

● Before facilitating or receiving digital assets through value transfer for a customer who does not have another business relationship with us.

● Regularly after establishing a business relationship with the customer; and

● When there are any changes or updates to:

● Lists and information provided by authorities to the payment service provider; or

● The natural person designated to act on behalf of the customer, related parties, or beneficial owners.

We will screen all value transfer senders and receivers against lists and information provided by authorities to determine the risk of money laundering or terrorist financing, and record the results of all screenings.

E. Enhanced Customer Due Diligence Measures

Politically Exposed Persons (PEPs)

We should use all reasonable means to determine whether the customer, any natural person acting on behalf of the customer, any related parties of the customer, or any beneficial owners or their family members or close associates are politically exposed persons (PEPs).

If a customer or any beneficial owners or their family members or close associates are identified as PEPs, we will perform at least the following enhanced due diligence measures in addition to regular customer due diligence:

● Obtain senior management approval for establishing and continuing the business relationship with the customer.

● Determine the sources of wealth and funds of the customer and any beneficial owners through reasonable means.

● Enhance monitoring of the business relationship with the customer during the relationship. We will increase the monitoring level for any transactions that appear unusual and upgrade the nature of the monitoring.

High-Risk Categories

We recognize that a customer may pose a higher risk of money laundering or terrorist financing in the following situations, including but not limited to:

● If the customer or any beneficial owner is from or located in a country/jurisdiction that is subject to enhanced anti-money laundering and counter-terrorism financing measures by the Financial Action Task Force (FATF), the payment service provider should consider any business relationship or transaction with such a customer as posing a higher risk of money laundering or terrorist financing.

● If the customer or any beneficial owner is from or located in a country/jurisdiction known for weak anti-money laundering/anti-terrorism financing measures, as determined by the payment service provider or notified by authorities or other foreign regulators, the payment service provider should assess whether such a customer poses a higher risk of money laundering or terrorist financing. We should apply enhanced customer due diligence measures for customers identified as posing higher risks of money laundering or terrorist financing or any customers notified by authorities as posing higher risks.

F. Handling of Bearer Transferable Instruments and Cash Payment Restrictions

We will not make any payments using bearer transferable instruments.

We will not accept any cash payments during our business operations.

G. Value Transfer Procedures (to be implemented if necessary) *

If we are a remittance institution, before executing a value transfer, we should:

● Identify the remitter and take reasonable measures to verify their identity (if not already done).

● Fully record the details of the value transfer, including but not limited to the date of the transfer, the type and value of the digital asset transferred, and the effective date.

If we are a remittance institution, we should specify in the memo or payment instructions attached to or associated with the value transfer:

● The name of the remitter.

● The remitter's account number (or a unique transaction reference number, if applicable).

● The name of the payee.

● The payee's account number (or a unique transaction reference number, if applicable).

For value transfers exceeding specific thresholds:

If we are a remittance institution, for value transfers above a certain threshold, we should identify and verify the identity of the remitter, including the memo or payment instructions attached to or associated with the value transfer, and the following:

● The remitter's address; or

● The remitter's registered address or business address (if different, the principal place of business should also be noted).

● The remitter's unique identification number; or

● The remitter's date and place of birth, and the registration or registration of the value transfer.

We should securely submit all information about the remitter and payee of the value transfer to the receiving institution and keep a record of all such information. If we, as a remittance institution, cannot meet these requirements, we will not execute the value transfer.

If we are a receiving institution, we should take reasonable measures to identify missing necessary information from the value transfer remitter or value transfer recipient.

If we are the receiving institution and pay the value of the transferred digital asset to the value transfer recipient in cash or cash equivalents, we should identify and verify the identity of the value transfer recipient (if not previously verified).

Before executing a value transfer, we should always review situations where information from the remitter or value transfer recipient is missing and record our follow-up actions.

If we are an intermediary institution, we will retain all information related to the value transfer. If we, as an intermediary institution, execute a value transfer to another intermediary institution or receiving institution, we should securely provide the information associated with the value transfer to that other intermediary institution or receiving institution.

If we are an intermediary institution receiving a value transfer, we should retain all information received from the remittance institution or other intermediary institutions for at least five years.

We should take reasonable measures to identify missing necessary information from the value transfer sender or recipient during the straight-through processing.

H. Record Keeping

We will retain appropriate records for at least 5 years as required.

I. Personal Data

We will protect customer personal data in accordance with applicable regulations.

J. Suspicious Transaction Reporting (STR)

We will notify the relevant authorities and submit suspicious transaction reports in accordance with the law. We will also retain all records and transactions related to such transactions and suspicious transaction reports.

K. Our Compliance, Audit, and Training Policies

In addition to other measures, we will appoint an anti-money laundering/combating the financing of terrorism compliance officer at the management level, maintain independent audit capabilities, and take proactive measures to provide regular anti-money laundering/combating the financing of terrorism training for employees.

Comprehensive Anti-Money Laundering/Combating the Financing of Terrorism Risk Assessment

We will conduct a comprehensive anti-money laundering/combating the financing of terrorism risk assessment in three stages:

Stage 1: Inherent Risk Assessment We will assess the following inherent risks:

● Customers or Entities: We will assess the customers and/or entities we deal with.

● Products or Services: We will pay attention to the target of services providing cryptocurrency over-the-counter transactions.

● Regional Scope: We must not deal with customers on the designated list of individuals and entities.

Stage 2: Risk Control Measures Assessment We will assess the risk control measures related to the above situations. We will monitor and apply enhanced due diligence to any and/or all customers we consider suspicious.

Stage 3: Residual Risk Assessment After assessing the risk control measures, we will evaluate the residual risk.