1. Overview
Gold Matching Network LLC (GMN Gold Markets) is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance.
This policy sets out the standards and controls GMN applies to prevent misuse of our platforms, onboarding processes, and account services for money laundering or related financial crime.
- Continuously monitor client and third-party transactions for policy compliance.
- Create and maintain records covering accounts, transactions, communications, and compliance procedures.
- Manage exposure to money laundering risk across the full client lifecycle.
- Apply enhanced controls for higher-risk profiles including politically exposed persons and higher-risk jurisdictions.
- Provide regular AML-related training to relevant staff.
- Report suspicious activity to the regulator in accordance with applicable law.
- Track legal changes and implement required procedural updates promptly.
2. What Is Money Laundering
Money laundering is the process of converting funds derived from illegal activity into assets that appear legitimate to hide or distort the original source of funds.
GMN takes a zero-tolerance approach to activity that seeks to move proceeds from fraud, corruption, or other criminal conduct through our systems.
3. Operational Position
GMN does not accept or pay out physical cash.
GMN does not directly accept digital currency.
GMN reserves the right to suspend any client operation where staff has a reasonable suspicion of money laundering or related criminal activity.
4. Know Your Customer and Due Diligence
All potential clients must complete GMN’s verification procedure before a business relationship is established.
Before account opening, GMN obtains and verifies sufficient identification and suitability evidence for customers and counterparty entities.
- Enhanced due diligence is applied to higher-risk clients and jurisdictions.
- Additional checks are applied to beneficial owners where there is elevated risk.
- Verification standards are reviewed for adequacy and consistency with applicable sanctions and PEP guidance.
5. Monitoring of Client Activity
GMN monitors transaction behavior and account patterns to identify activity inconsistent with stated business purpose, account profile, or normal usage patterns.
Any transactions that appear unusual, unexplained, or inconsistent with legitimate trading and account activity are escalated for review.
6. Record Keeping
GMN retains records to support AML compliance, investigation, and audit requirements.
Documented records may include identification records, transaction records, monitoring logs, and suspicious activity documentation.
- Records are retained for a minimum period of five (5) years after account closure.
- Retention supports operational defensibility, legal defensibility, and regulator requests.
7. Suspicious Activity Handling
All attempts to execute transactions that GMN suspects are linked to money laundering or other criminal activity are assessed under internal escalation procedures.
GMN reserves the right to suspend client activity where a transaction is suspicious and pending compliance review.
- Suspicious activity is documented and reviewed by the compliance function.
- Reporting is made as required by governing regulation.
8. Regulatory Reporting and Compliance
GMN reports suspicious activity in accordance with legal and regulatory obligations applicable to Gold Matching Network LLC’s operations.
Where required, reports are sent to the Financial Services Authority (FSA) of Saint Vincent and the Grenadines and any other competent authority with jurisdictional mandate.
- Policy changes are reviewed when legislation or regulations change.
- Internal procedures are updated to reflect evolving risk and compliance guidance.
- All relevant teams are informed of updates affecting onboarding and monitoring requirements.
9. Document Updates
This AML Policy may be updated from time to time to reflect legal, operational, and risk-management developments.
The revised effective date is shown at the top of this page.
Contact the Compliance Function
For reporting, document requests, and regulatory questions, use the general contact channels at info@gmnexchange.com.