GatewayCrypto
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Our policy is designed to prevent and mitigate the risks of our involvement in any kind of illegal activity.

For purposes of this Policy, “Company”, “us,” “we,” or “our” refer to NEXT DAY TECH LLC, register number 3493, address: Euro House, Richmond Hill Road, P.O. Box 2897, Kingstown, St. Vincent and the Grenadines, a company which operates Gatewaycrypto.io website and its services (Hereafter “site” or “website” and or “services”).

The purpose of this document is to provide the Company’s partners, clients, vendors, contractors, employees, regulators, law enforcement and other concerned stakeholders with a high-level overview of the Company’s AML/CTF compliance regime elements and procedures. By no means this document shall not be read as an entire set of all policies, procedures and controls in place implemented by the Company for prevention of money laundering, financing of terrorism and other forms of illicit activity.

We do not offer our Services for use to persons or legal entities located in or have their habitual residence or registered office in the Prohibited Jurisdiction. For as long as you maintain your registered account at our website, you represent and warrant that you are not located in or a resident of the Prohibited Jurisdiction. List of “Prohibited Jurisdictions” can be found in the Terms of Use.

Both international and local regulations require us to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity of our customers.

Money Laundering

The Company understands “money laundering” as:

  • The conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing its illicit origin.
  • The concealment or disguise of the true nature, source, location, disposition, or ownership of property derived from criminal activity.
  • The acquisition, possession or use of property, knowing it was derived from criminal activity.
  • Participation in, association with, or attempts to commit any of the above actions.
Terrorist Financing

This means the provision or collection of funds, directly or indirectly, with the intention or knowledge that they will be used to carry out terrorist activities. Terrorist activity aims to intimidate a population or compel a government by causing death, serious harm, or major disruption to essential services.

Gatewaycrypto will perform a risk-based due diligence and collect information on each prospective client to assess their risk profile. We conduct business to the highest ethical standards and will not engage with individuals or entities that could harm our reputation.

For risk assessment, we consider the following categories:

  • Customer risk
  • Geographical risk
  • Product risk
  • Delivery channel risk

The risk level attributed to a customer is revised periodically based on their activity.

The Compliance Officer is authorized to ensure the effective implementation and enforcement of the AML Policy. Their responsibilities include:

  • Collecting customers' identification information.
  • Providing relevant KYC/CDD, including detection of PEP status and final beneficiaries.
  • Establishing and updating internal policies and procedures.
  • Monitoring transactions and investigating significant deviations.
  • Implementing a records management system.
  • Updating risk assessments regularly.
  • Providing law enforcement with required information.
  • Providing sanctions screening.
  • Providing training to personnel.
  • Reporting suspicious activity to responsible authorities.

The Compliance Officer interacts with law enforcement agencies involved in preventing illegal activities.

We have implemented strict rules of procedure to manage AML/CTF risks. All employees must adhere to these rules, which include procedures for applying due diligence measures, managing customer risk profiles, handling suspicious activity reporting, and data retention.

Due Diligence Measures
  1. Identification of a customer and verification of submitted information.
  2. Identification of the beneficial owner and understanding the ownership structure.
  3. Understanding the nature of business relationships.
  4. Gathering information on whether a person is a Politically Exposed Person (PEP).
  5. Ongoing monitoring of the business relationship.
Simplified Due Diligence (SDD)

SDD may be applied where the risk of money laundering is assessed as lower than usual, provided that sufficient monitoring is maintained to detect unusual transactions.

Enhanced Due Diligence (EDD)

EDD is always applied in high-risk situations, including when:

  • There are doubts about the customer's identity or documents.
  • The customer is a PEP (or family member/associate).
  • The customer is from a high-risk third country or a jurisdiction with weak AML/CTF systems.

Politically Exposed Persons (PEP)

A PEP is a person entrusted with prominent public functions, such as heads of state, ministers, members of parliament, judges of supreme courts, ambassadors, and high-ranking military officers. This definition also extends to their family members and close associates. PEPs are subject to enhanced scrutiny due to the risk of abuse of public office.

Sanctions Screening

We screen all customers against international sanctions lists to mitigate legal and reputational risks. The screening is performed, at minimum, against the following lists:

  • UN Sanctions
  • EU Sanctions
  • OFSI-UK Sanctions
  • OFAC-US Sanctions
  • Sanctions under the International Sanction Act

All potential matches are escalated to the Compliance Officer for review.

Suspicious Activity Monitoring and Reporting

If we identify any activity suspected to be related to criminal proceeds or terrorist financing, our Compliance Officer will report it to the Financial Services Authority of St. Vincent and the Grenadines (FSA) within five working days. We are prohibited from informing any person that a report has been or will be filed about them.

Data Retention

Documents and information used for client identification and verification will be retained for at least five years after the termination of the business relationship. All personal data is protected and used only for the purpose of preventing money laundering and terrorist financing.

Training

The Compliance Officer ensures all employees receive ongoing training to stay aware of their legal obligations and the latest developments in AML/CTF prevention.

Policy Updates and Acceptance

Changes to this AML policy

Gatewaycrypto has the discretion to update this AML policy at any time. When we do, we will post a notification on this page of our Site. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this AML policy periodically and become aware of modifications.

Your acceptance of this Policy

By using this Site or our Services you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes. This AML Policy is a client version and is not the full version which is used by us. You understand and agree that the AML Policy used by us cannot be shown in full as to prevent manipulations and sanctions breaking.

Contacting Us

If you have any questions about this AML Policy, the practices of this site, or your dealings with this site, please contact us.

compliance@gatewaycrypto.io