Last updated: July 2026
1. Scope
This policy applies to all gFinOS account holders, merchants, government partners, and platform participants globally. It is designed to detect and prevent money laundering, terrorist financing, sanctions evasion, fraud, and other financial crime.
2. Framework
Our program is designed with reference to Financial Action Task Force (FATF) recommendations, applicable Basel Committee guidance, and local requirements in each jurisdiction we operate in. Named officers are responsible for compliance oversight.
3. Customer Due Diligence (KYC)
- Identity verification of every individual account holder (document + liveness/biometric).
- Address verification where required by jurisdiction.
- Enhanced verification for high-risk customers, politically exposed persons (PEPs), and cross-border activity.
- Alternative verification pathways for users without conventional government identity documents, subject to enhanced controls.
4. Business Due Diligence (KYB)
- Verification of legal entity, beneficial owners (25%+), directors and controlling persons.
- Review of business activity, expected volumes, and cross-border exposure.
- Ongoing screening against sanctions and adverse-media lists.
5. Government partners (KYG)
Sovereign revenue wallets are activated only after verification of the requesting government authority, its authorized officials, and the treasury accounts to which funds are released.
6. Sanctions screening
All parties are screened at onboarding and on an ongoing basis against consolidated sanctions lists (including OFAC, EU, UN, HMT and applicable national lists). Blocked or restricted parties are prevented from transacting.
7. Transaction monitoring
Every transaction is monitored in real time against rules and machine-learning models tuned for money laundering, terrorist financing, fraud, and account takeover. Suspicious activity is escalated to our compliance team.
8. Reporting
Where required by law, gFinOS files Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), tax remittance reports, and cross-border reporting to the appropriate financial intelligence units and tax authorities.
9. Record keeping
KYC/KYB records, transaction records, and internal reports are retained for the periods required by applicable law (typically 5–10 years after account closure).
10. Training
gFinOS staff receive AML/CTF training at onboarding and at least annually thereafter, with role-specific training for compliance, risk, and customer operations teams.
11. Reporting concerns
If you suspect financial crime involving an gFinOS account, contact us via the Help Center. Anonymous reporting is supported.