Aml Policies

Introduction and Regulatory Basis

Goawin is committed to preventing money laundering and the financing of terrorism. This AML/CTF Policy sets out the controls and procedures Goawin employs to identify, assess, and mitigate material money-laundering and terrorist-financing risks arising from customer onboarding, ongoing activity, and the processing of payments on the platform.

Scope and Application

This policy applies to all Goawin customers and to all accounts, transactions, and payment methods under Goawin's platform, including deposits, withdrawals, and internal transfers between user accounts, regardless of device or channel. It governs the actions of Goawin and its employees, contractors, and agents in relation to AML/CTF compliance.

Risk-Based Customer Due Diligence

Goawin applies a risk-based approach to customer due diligence (CDD). The risk assessment considers geographic risk associated with the user’s country of residence or operation; customer risk factors such as user type, ownership structure, and purpose of activity; and transaction risk including expected velocity, volume, and mixing of payment instruments. Based on risk, Goawin assigns a risk rating to each customer and tailors verification and ongoing monitoring accordingly.

Identity Verification and Documentation

Standard Verification is triggered when the aggregate value of the user’s deposits or withdrawals reaches or exceeds USD 1,000 within any rolling 12-month period, or when a single transaction equals or exceeds USD 1,000. Standard Verification requires the following evidence:

  • Identity: a copy of a government-issued photo ID (front and back) or an internationally recognized passport; in the absence of photo ID, an official birth certificate accompanied by a clear selfie of the user holding the certificate.
  • Address: a document confirming residence dated within the last three months (utility bill, bank statement, government document) showing the user’s full name and residential address.
  • Payment method verification: for card payments, a copy of the card showing the cardholder name and the first six and last four digits; all but the first six digits and last four digits may be redacted or blocked. For electronic wallets, proof of ownership such as a screenshot of the wallet account with the registered email; for bank transfers, a bank statement reflecting the deposit.
  • Selfie/biometric verification: a live photograph or video as requested by Goawin to confirm identity, and any additional data or documents as required by the risk assessment.

Enhanced Due Diligence (EDD)

Goawin applies Enhanced Due Diligence for higher-risk customers or transactions. Scenarios triggering EDD include potential Politically Exposed Persons (PEPs) or family members; residence or domicile in a jurisdiction identified by credible sources as high-risk for AML/CFT controls or with deficiencies in anti-money laundering regimes; other indications of elevated risk or incomplete verification data. Under EDD, Goawin shall obtain additional documentation or information to ascertain the source of wealth and the origin of funds, and shall seek senior management approval before permitting ongoing activity. The company may require on-site or video-based verification and additional data consistent with local law.

Ongoing Monitoring and Suspicious Activity

Goawin conducts ongoing monitoring of all active customer accounts for indicators of suspicious activity. Indicators include, but are not limited to: unusual deposit patterns, rapid changes in funding sources, use of multiple payment cards or wallets in a short period, geolocation inconsistencies, device or IP address mismatches, or reluctance to provide verification. When suspicious activity is identified, the matter is escalated to the Compliance and Anti-Fraud function for assessment. If necessary, Goawin may report the activity to appropriate regulators or law enforcement in accordance with applicable law.

Transaction Monitoring and Funds Integrity

All deposits and withdrawals must be attributable to the account holder. Goawin adheres to the following rules: third-party payments are prohibited; the name on a payment card must match the Goawin account holder’s name; for wallet payments, the wallet account email must match the registered user email. If a deposit is funded by a payment method that cannot be reliably verified as belonging to the user, withdrawals will be processed to a payment instrument that can be reliably mapped to the user’s ownership. Goawin does not accept payments from anonymous instruments such as unverified cryptocurrencies or anonymous wallets, and does not process withdrawals to wallets or accounts where ownership cannot be confirmed.

Record-Keeping and Data Protection

Goawin shall retain all documents and data obtained in the course of verification and ongoing AML/CFT controls in compliance with applicable law, including data protection regulations. Records shall be stored securely and retained for the minimum period required by law, and shall be accessible to regulators on demand. Goawin processes personal data in accordance with its Privacy Policy and applicable data protection legislation.

Amendments to the Policy

This policy may be amended at Goawin’s sole discretion. Goawin shall provide notice of material changes to registered users in accordance with internal procedures. Continued use of the platform after notice constitutes acceptance of the updated policy.

Compliance and Contact

Users may contact Goawin Compliance through the platform’s support channels for questions related to AML/CTF controls, verification requirements, or data subject rights. Goawin will respond in accordance with applicable legal timeframes.