Goat Spins maintains a strict Anti-Money Laundering (AML) and Know-Your-Customer (KYC) program designed to prevent misuse of our platform for money laundering, terrorist financing, or other illicit activities. This policy applies to all Goat Spins users, transactions, and business relationships and governs on-boarding, ongoing monitoring, and escalation procedures in compliance with applicable laws and international standards.
This policy covers: (a) customer due diligence and verification, (b) ongoing monitoring of user activity, (c) screening against sanctions and high-risk indicators, (d) reporting of suspicious activity, (e) record keeping, and (f) employee training. It applies to all Goat Spins staff, contractors, and third-party service providers acting on our behalf.
The Goat Spins Board retains ultimate responsibility for AML/CTF compliance. We appoint a designated AML/CTF lead (the AML Officer) responsible for day-to-day implementation, oversight, and management of this policy. The AML Officer ensures adequate resources, independent authority, and timely reporting to senior management on compliance matters.
We apply a risk-based CDD framework, commencing at account registration and continuing through ongoing monitoring. Verification is conducted using reliable and independent sources and may involve third-party screening for sanctions and PEP status.
EDD is applied for higher-risk scenarios, including but not limited to:
EDD measures may include additional identity verification, source-of-funds and source-of-wealth substantiation, expanded transaction monitoring, and management approval to commence or continue a business relationship.
We perform ongoing, risk-based monitoring of user activity and transactions. Data maintained for KYC purposes is periodically reviewed and updated, with heightened monitoring for high-risk accounts. The monitoring program includes automated screening and manual review where appropriate, with procedures to escalate to the AML Officer for further analysis.
Goat Spins screens against applicable sanctions lists and restricted jurisdictions. Access from or transactions with high-risk or sanctioned jurisdictions may be blocked or subject to enhanced due diligence. We also screen for adverse associations and comply with all applicable international sanctions regimes.
Our platform employs a combined automated and manual monitoring approach. Key components include:
We may refuse or suspend a user’s account or terminate existing relationships for reasons including, but not limited to, failure to provide satisfactory identification, falsified documents, negative findings in screening, PEP-related risk that cannot be adequately mitigated, or suspicion of ML/TF activity. We may also restrict access from restricted or high-risk jurisdictions as part of compliance measures.
We retain AML/CTF records for not less than five (5) years after the end of the business relationship or the final transaction, or longer if required by applicable law. Records include identification documents, verification results, transaction details, correspondence related to AML/CTF matters, internal investigation files, and training records. Records are stored securely and made available to competent authorities upon legitimate request in accordance with data protection laws.
Any employee who identifies or suspects potential ML/TF must promptly report to the AML Officer. The AML Officer will investigate internal reports and, if warranted, file a Suspicious Activity Report (SAR) with the competent Financial Intelligence Unit or other authorities in accordance with applicable law. We will not disclose to the customer that a SAR has been filed, and we will cooperate with law enforcement and regulatory authorities as required, subject to legal constraints.
Goat Spins provides ongoing AML/CTF training to all relevant personnel. Training covers applicable laws and regulations, internal procedures, red-flag indicators, KYC and due diligence requirements, reporting processes, and record-keeping obligations. Training is conducted at least annually and updated as regulatory changes occur.
This AML/CTF policy is a living document. We review and update it at least annually or more frequently when regulatory changes, updates to risk assessments, or significant business changes necessitate revisions. Significant amendments require approval by the AML Officer and senior management.
All handling of personal data for AML/CTF purposes complies with applicable data protection laws and Goat Spins’ Privacy Policy. Personal data is processed solely for identity verification, risk assessment, monitoring, reporting, and regulatory compliance.