AML Policy

Client Due Diligence (CDD) Procedures

At GSI-Group, we consider the implementation of rigorous Client Due Diligence (CDD) procedures essential in mitigating risks associated with money laundering and terrorist financing. CDD encompasses the accurate identification and verification of a client's identity using reliable, independent source documents, data, or information. This crucial process is initiated at the onset of the business relationship and maintained throughout its duration to ensure continual compliance and risk management.

Individual Client Identification Requirements:

• Full name
• Date of birth
• Country of residence/location
• Mobile telephone number and email address

Corporate Client Identification Requirements:

• Full company name
• Registration number and date
• Country of registration/incorporation
• Registered address
• Mobile telephone number and email address
• Names of Directors and Shareholders, including Ultimate Beneficial Owners (UBOs)

Documentary Requirements for Identity Verification:

Individual Clients:

• High-resolution photos of passport, national ID, or a valid driving license, along with a recent, clear selfie.

Corporate Clients:

• High-resolution copies of incorporation documents, business licenses, and documents evidencing company structure and ownership.

Address Verification Documents:

• Utility bills, local authority tax bills, bank statements, or bank reference letters, all issued within the last three months and bearing the client's name. GSI-Group leverages both automated systems and third-party identity verification solutions, complemented by manual checks by our personnel. Client details are verified against electronic databases for identity confirmation, legal status, and any pertinent risk factors such as criminal records, political exposure, and sanctions lists.

Third-Party Verification System Standards:

• Registration with the Data Protection Commissioner in its operating country.
• Access to extensive electronic databases for both historical and current data.
• Real-time source verification, with alerts for any significant data changes.
• Detailed verification records to support compliance and auditing efforts.
• For high-risk relationships, GSI-Group may undertake enhanced due diligence, including inquiries into the origin of funds, and continuous monitoring and reassessment of the business relationship.

AML Compliance Personnel:

AML Compliance Officer:

• High-resolution photos or copies of utility bills (issued within the last three months)

Employees:

• All personnel, including managers and directors, are expected to understand and implement this AML policy. Those directly involved in AML functions receive specialized training and are subject to rigorous screening processes.

Employee Training Program:

• We conduct in-depth AML training for all relevant employees, covering the full spectrum of AML/TF risk detection, management, and compliance. Supervisors provide ongoing guidance on policy, procedures, and the nuances of client interactions within the forex and trading platform environments.
• GSI-Group's AML training ensures all team members are proficient in identifying and managing the complexities of AML/TF risks, thereby safeguarding our operations and clientele from illicit activities.