Last updated: May 23, 2026
INTRODUCTION
GoMining (BVI) Limited is committed to the highest ethical and legal standards. This Policy outlines our approach to preventing money laundering, terrorist financing, and sanctions violations.
The Company operates under the laws of the British Virgin Islands, including the Anti-Money Laundering Regulations (Revised 2020) and the National AML/CFT Policy. We also voluntarily align with FATF international standards and applicable U.S. sanctions requirements.
Senior management maintains a zero-tolerance policy toward financial crime. All employees are required to be vigilant and report any suspicious activity to the Compliance Officer (CO).
SCOPE
This Policy applies to all employees, officers, directors, and independent contractors of the Company. All personnel must read, understand, and sign the Compliance Acknowledgement Form within 14 days of receiving this Policy.
Non-compliance may result in disciplinary action up to and including termination, as well as potential civil or criminal penalties.
CLIENT ONBOARDING AND DUE DILIGENCE
All clients undergo Customer Due Diligence (CDD) before business relations are established. Required information includes full name and date and place of birth (or incorporation for entities), government-issued photo ID and selfie verification, proof of residential or registered address issued within 3 months, and primary citizenship and email address.
The Company applies a risk-based approach. Clients from high-risk jurisdictions or flagged during screening may be subject to Enhanced CDD, which requires senior management approval, source of funds verification, and ongoing enhanced monitoring.
Clients who are Politically Exposed Persons (PEPs) or their close associates are automatically subject to Enhanced CDD.
PROHIBITED JURISDICTIONS
The Company does not conduct business with clients located in, incorporated in, or beneficially owned by persons in the following jurisdictions: Afghanistan, Cuba, Iran, Myanmar, North Korea, Somalia, South Sudan, Syria, Yemen, the Crimea region of Ukraine, the Donetsk People’s Republic (DNR), and the Luhansk People’s Republic (LNR).
The Company enforces this through IP geoblocking, KYC verification, and blockchain analytics screening.
SANCTIONS
The Company complies with BVI government sanctions and voluntarily adheres to U.S. OFAC sanctions. Employees are prohibited from transacting with any individual or entity on the OFAC SDN List or any entity 50% or more owned by a sanctioned person.
Comprehensive U.S. embargoes currently apply to Iran, Cuba, North Korea, Syria, Myanmar, and the Crimea, DNR, and LNR regions of Ukraine.
Any blocked digital assets will be held in a segregated cold storage wallet pending resolution.
MONITORING AND SUSPICIOUS TRANSACTIONS
The Company continuously monitors client transactions. Employees must report to the CO any transactions that are unusually large or complex with no clear business purpose, from or to high-risk geographic locations, above thresholds of $10,000 for a single transaction, $50,000 within 14 days, or $100,000 within 30 days, or inconsistent with the client’s known profile or history.
Employees must not discuss suspicions with colleagues, managers, or the client. Tipping off is a criminal offence.
RECORD KEEPING
CDD records must be retained for a minimum of 7 years. Transaction records must be retained for a minimum of 5 years after completion. All records must be available for regulatory review upon request.
TRAINING
All employees must complete AML/CFT training at least once every two years. The CO is responsible for delivering, recording, and assessing the effectiveness of training.
REGULATORY INQUIRIES
If contacted by any government official or regulator, employees must refer the inquiry to the CO immediately, not engage in discussion or take independent action, and forward all documentation received to the CO.
REPORTING VIOLATIONS
Employees must report known or suspected policy violations to the CO. The Company maintains a non-retaliation policy for good-faith reports.
POLICY REVIEW
This Policy is reviewed at least annually by the CO to reflect legislative changes, best practices, and the outcome of risk assessments.
For questions, contact the Compliance Officer at contact@gominin.com.
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