> For the complete documentation index, see [llms.txt](https://golden-shield-digital-treasury-b.gitbook.io/product-docs/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://golden-shield-digital-treasury-b.gitbook.io/product-docs/others/aml-cft-policy.md). # AML/CFT Policy ### 1. Introduction to AML Policy Guided by the rules and regulations of the **BVI Financial Services Commission (FSC)**, the purpose of this policy is to set the GDB Platform’s internal practices, procedures, and controls for preventing **money laundering (AML)**, **terrorist financing (CFT)**, and ensuring full adherence to **Know-Your-Customer (KYC)** principles. This policy is established and updated by the appointed **Money Laundering Reporting Officer (MLRO)**, who also serves as Compliance Officer for the GDB Platform. The policy applies to all employees, contractors, and service providers operating within the GDB ecosystem. The AML/CFT Policy has been prepared to comply with: * The BVI **Regulatory Code (2020, revised)** * The **Anti-Money Laundering and Terrorist Financing Code of Practice (2020, revised)** * The **Anti-Money Laundering and Terrorist Financing (Amendment) Code of Practice (2022)** * Relevant FATF recommendations and international standards The **Financial Investigation Agency (FIA)** is the authority where suspicious activities are reported. The MLRO ensures full implementation of GDB’s AML/CFT regime and monitors adherence to internal controls and external obligations. All GDB employees and node operators are obliged to report suspicious activity or transactions involving **GDB or GDO tokens, user wallets, or digital asset transfers** to the MLRO. The MLRO will escalate and report such activities to the **FIA**. *** ### 2. Compliance Monitoring The **Board of GDB** oversees AML/CFT arrangements. The **Compliance Officer**, supported by external advisors if required, is responsible for: * Enforcing this AML/CFT policy across all GDB operations (issuance, trading, custody, redemption). * Maintaining and updating internal controls in line with FSC and FATF requirements. * Identifying compliance risks specific to **digital assets and sovereign bond tokenization**. * Conducting compliance monitoring programs and periodic reviews. * Ensuring accurate and timely filing of reports with regulators. * Addressing breaches, incidents, and reporting findings to the Board. *** ### 3. Client Onboarding: Know Your Customer (KYC) #### 3.1 KYC for New Accounts All **investors, wallet-holders, and platform participants** must undergo KYC before accessing GDB’s products (e.g., GDB governance token purchases, GDO bond package subscriptions). Required data: * Full legal name (and aliases if applicable). * National ID, passport, or incorporation/business registration number. * Residential or business address. * Date of birth or incorporation. * Nationality or jurisdiction of incorporation. #### 3.2 Legal Entities For corporate clients, GDB requires: * Identification of ownership, governance, and control structures. * Identification of connected parties (directors, beneficial owners). * Proof of incorporation, existence, and powers. #### 3.3 Authorized Representatives Where natural persons act on behalf of legal entities, GDB verifies: * Identity (full name, ID/passport, residential address, date of birth). * Authority (board resolution, mandate, power of attorney). * Specimen signatures. #### 3.4 Ongoing Monitoring * All **wallets and transactions** are continuously monitored for suspicious activity. * **Biennial reviews** of standard-risk clients’ CDD data; **annual reviews** for high-risk. * Enhanced monitoring applied to complex or unusual on-chain transactions. *** ### 4. Anti-Money Laundering & Counter-Terrorist Financing (AML/CFT) * GDB Platform adopts a **risk-based approach** to assess AML/CFT risks of investors, products, jurisdictions, and token flows. * All risks are documented, updated annually, and approved by the Board. * GDB aligns with **FATF recommendations** for virtual asset service providers (VASPs), including the **Travel Rule** for transactions over USD 1,000. *** ### 5. GDB’s Responsibilities * Exercise due diligence for all **GDB/GDO wallet-holders and participants**. * Conduct operations in line with **high ethical standards**. * Avoid onboarding clients or processing transactions linked to money laundering or terrorist financing. * Cooperate fully with global regulators and law enforcement in relevant jurisdictions. *** ### 6. Risk-Based Approach * Each investor is assigned a **risk rating** (low, medium, high). * Risk factors include nationality, industry, PEP status, wallet activity, and transaction patterns. * Reviews: * Low risk: every 3 years * Medium risk: every 2 years * High risk: annually * GDB also conducts **enterprise-wide AML risk assessments** every 2 years. *** ### 7. Onboarding Approval Before onboarding, GDB requires: * Client profile and account opening forms * Identification of connected/authorized persons * Beneficial ownership declaration * Screening against sanctions and watchlists * Enhanced Due Diligence for high-risk clients (Board approval required) * Compliance with **Travel Rule** for crypto transactions > USD 1,000 *** ### 8. Customer Due Diligence (CDD) * **Beneficial Owners:** Identify ultimate beneficial owners (UBOs) in all legal persons. * **Simplified CDD:** Allowed only for low-risk clients and not for high-risk jurisdictions. * **Enhanced CDD:** Mandatory for PEPs, high-risk jurisdictions, and suspicious clients. Includes Board approval, proof of source of wealth/funds, and intensified monitoring. * **Screening:** Continuous screening against global AML/CTF lists and wallet-risk databases (e.g., blockchain analytics providers). *** ### 9. Record-Keeping * GDB maintains records of all **wallet addresses, transactions, CDD files, and risk assessments** for at least **5 years** post-termination of business. * All records are securely stored and easily retrievable for regulatory inspection. *** ### 10. Suspicious Transaction Reporting * Employees must escalate suspicious **on-chain transfers, unusual redemption patterns, or wallet activities**. * MLRO assesses objectively and reports to the **FIA** when warranted. * Examples of red flags: * Unusually large GDB/GDO transfers. * Attempted anonymous trades or unverified wallets. * Transactions involving high-risk jurisdictions. * Use of mixing services or privacy coins linked to GDB wallets. *** ### 11. Staff Training * All staff and relevant technical operators must undergo **annual AML/CFT training**. * Training covers AML regulations, blockchain-specific red flags, and GDB internal procedures. * Knowledge testing is conducted periodically to ensure staff readiness. *** ✅ This version preserves **regulatory compliance detail** but adapts it to the **GDB digital bond platform**, with explicit mention of **GDB/GDO tokens, wallets, and exchanges**.