1. Introduction
Onism Limited (“Goated” or the “Company”), operates the website www.goated.com under Licence No. ALSI-202411063-FI2 by the Government of the Autonomous Island of Anjouan, Union of Comoros.
This Anti-Money Laundering Policy ("AML Policy") outlines Goated's strategy for preventing and combating money laundering and terrorist financing risks.
2. Objective and Policy Statement
Goated strictly prohibits the use of its platform for any illegal activity, including money laundering, terrorist financing, and sanctions violations. Our AML Policy outlines the measures and procedures implemented to manage these risks and ensure compliance with global best practices.
3. Know Your Customer (KYC)
Goated has implemented this policy in order to proportionally manage and mitigate the money laundering and terrorist financing risks faced by Goated. Goated applies appropriate know-your-customer ("KYC") and ongoing monitoring measures as required by law.
a. KYC Measures
Goated incorporates a risk-based Customer Due Diligence (CDD) process to develop a customer risk profile. This involves collecting user information at the onboarding stage and monitoring user activity as per below:
Collecting Customer Information - Goated collects details of each user to form a reasonable belief that it knows the identity of its users. These details may include the user's wallet address, name, date of birth, address, country, which all form the KYC information. A third-party service provider may support Goated to determine the validity of the information provided by its users.
Geo-blocking for Prohibited or Sanctioned Jurisdictions - Relevant users are notified while onboarding that Goated does not offer services in jurisdictions where such services are not permitted to be offered and requires customers to declare that they are not located in a prohibited jurisdiction. Goated has implemented IP address-based geo-blocking for those jurisdictions. This also extends to jurisdictions subject to United States, European Union, or other global sanctions or watchlists, including Iran, Cuba, North Korea, Syria and the Crimean region of Ukraine, and users have to declare that they are not personally subject to international sanctions.
Screening for Sanctioned Parties - Goated may screen a user's wallet address against applicable sanctions databases, through third-party blockchain forensics vendors such as Chainalysis.
b. Transactions Monitoring
Goated performs ongoing monitoring of its users in order to detect suspicious behaviour potentially indicative of illicit activity.
Transaction Monitoring for Prohibited or Sanctioned Jurisdictions & Parties - Goated employs a combination of manual and automated transaction monitoring processes to identify "red flag" behaviour. When such behaviour is detected, Goated may refuse to process any withdrawal attempts or request additional information from the customer. Customers can provide additional information to contest any suspensions as part of Goated's ongoing transaction monitoring and due diligence procedures.
Transaction Monitoring for Sanctioned Parties - Goated will periodically screen user wallet addresses against applicable sanctions databases.
Identification of Unusual Activity - Goated will monitor user activity for unusual size, volume, transactions or behaviour, considering any other relevant risk factors.
Anti-Mixing Measures - Goated does not allow the use of anonymity-enhancing technologies such as mixers, tumblers or certain coins and tokens. Users who choose to connect their wallet to the account can also only connect a singular wallet to the account as an anti-mixing measure. Goated may also take steps to further address suspicious deposit or withdrawal patterns on a case-by-case basis, depending on the perceived level of risk.
Chainalysis Review - Crypto deposit and withdrawal will be analysed using Chainalysis to detect signs of fraud or suspicious activity. If potential illicit behaviour is flagged, the user's account will be suspended and reviewed. High-risk accounts may be required to provide adequate proof of wealth. Goated reserves the right to block withdrawals to certain "high-risk" addresses, based on risk assessments conducted in partnership with Chainalysis.
Withdrawal Threshold KYC - Furthermore, any account's withdrawal function may be suspended once it reaches a withdrawal threshold dependent on the account's risk profile, assessed according to Goated's sole discretion, until adequate due diligence has been carried out.
Multiple Account Usage Prevention - Goated prohibits users from creating multiple accounts by ensuring that the same email address cannot be used more than once. Additionally, if identical KYC details are detected across accounts, those accounts may be suspended or permanently disabled.
c. Enhanced Due Diligence
On Goated, if a red flag is triggered, the relevant user's account will be suspended and Goated will perform enhanced due diligence ("EDD") which may include and is not limited to, obtaining user information such as:
Full legal name;
Date of birth;
Country of citizenship;
Permanent address;
Identification documents (e.g. a passport); and
Source of funds
Goated may use third-party providers to verify any of this information.
Goated also prohibits and blocks or suspends users who:
Do not provide the identification information requested;
Provide fake identification documents;
Are from prohibited or sanctioned jurisdictions;
Are subject to US, European Union or other global sanctions or watchlists; or
Are addicted to gambling
Goated reserves the right to block and suspend any users for any other reason at its sole discretion.
4. Reporting
If a user is identified to be on a sanctions list or linked to criminal activities, Goated will make an appropriate report to the relevant authority.
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