AML Policy

Introduction

At GSC ("Company," "we," "our," or "us"), we are dedicated to upholding the highest ethical standards and ensuring full compliance with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws.

This Anti-Money Laundering Policy ("Policy") sets out the measures we take to prevent, detect, and report any suspicious activities related to money laundering or the financing of terrorism.

Our Objectives

• Ensure compliance with AML/CTF regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and relevant international standards.
• Prevent the misuse of our services for illegal activities.
• Establish strong processes for verifying clients and monitoring transactions.
• Report any suspicious activities to the proper authorities in a timely manner.
• Promote a culture of awareness and compliance among our employees.

Who This Policy Applies To This Policy covers:

• All employees, contractors, and officers of GSC.
• Clients, partners, and any other entities doing business with us.
• All products, services, and financial transactions associated with GSC.

Understanding Money Laundering

Money laundering is the process of disguising illegally obtained funds to make them appear legitimate. It typically involves three stages:

• Placement – Introducing illicit funds into the financial system.
• Layering – Moving money through multiple transactions to obscure its origin.
• Integration – Using the laundered funds in the economy as though they were legally earned.

Our AML Program

• Know Your Customer (KYC): Before doing business with us, all clients must go through a verification process. We collect and verify key details such as full name, date of birth, address, government-issued ID, and business ownership information. High-risk clients, including politically exposed persons (PEPs) and those from high-risk regions, undergo enhanced due diligence (EDD).
• Transaction Monitoring: We monitor transactions for any unusual or suspicious activity. Transactions that do not align with a client’s profile or expected behavior may be flagged for further review.
• Record Keeping: We securely store all relevant client information, transactions, and communications for the legally required period. These records are available for regulatory audits and investigations.
• Reporting Suspicious Activity: Any suspicious activities are promptly reported to the appropriate authorities, such as the Financial Crimes Enforcement Network (FinCEN). Employees are trained to recognize and report red flags, including unusual transaction patterns or inconsistent client behavior.
• Risk Assessments: We regularly assess risks related to money laundering and terrorist financing. These assessments help us refine our controls and adjust to emerging risks.
• Employee Training: All employees receive ongoing training to stay informed about AML/CTF obligations and reporting procedures. Employees must confirm their understanding of this Policy and their role in maintaining compliance.
• Independent Audits: We conduct periodic independent audits to review the effectiveness of our AML program. These audits help ensure we are meeting all regulatory requirements.

Roles & Responsibilities

AML Compliance Officer (AMLCO):

• Oversees the implementation and enforcement of the AML program.
• Provides training, assesses risks, and liaises with regulatory authorities.

Management:

• Ensures the AML program is properly resourced and supported.

Employees:

• Must understand and follow this Policy.
• Are required to report any suspicious activity to the AMLCO immediately.

Client Cooperation

We require all clients to:

• Provide accurate and up-to-date information during the onboarding process.
• Notify us of any changes to their personal or business details.
• Avoid engaging in any activities that may raise AML/CTF concerns.

Failure to comply with these requirements may result in account suspension, termination, or reporting to regulatory authorities.

Confidentiality & Data Protection

All client information provided under this Policy is handled with the highest level of confidentiality. We use secure systems to protect client data and comply with applicable data protection laws, such as the General Data Protection Regulation (GDPR) and relevant U.S. privacy laws.

Consequences of Non-Compliance

Non-compliance with AML/CTF laws can result in:

• Criminal and civil penalties for both the Company and individuals involved.
• Loss of business reputation and potential regulatory sanctions.
• Significant fines and possible imprisonment for those who knowingly participate in money laundering.

We are committed to cooperating with law enforcement and regulatory agencies to prevent and address non-compliance.

Policy Updates & Review

This Policy is reviewed regularly and updated as needed to align with changes in laws, regulations, or business operations. The "Effective Date" above reflects the most recent update.