AML/KYC Policy

Introduction

Goldenlovi Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Goldenlovi being involved in any kind of illegal activity. Both international and local regulations require Goldenlovi 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 from its Users.

AML/KYC Policy covers the following matters:

• 1. Verification procedures.
• 2. Monitoring Transactions.
• 3. Risk Assessment.

1. Verification procedures.

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Goldenlovi establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

1.1. Identity verification.
Goldenlovi’s identity verification procedure requires the User to provide Goldenlovi with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Goldenlovi reserves the right to collect User’s identification information for the AML/KYC Policy purposes. Goldenlovi will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Goldenlovi reserves the right to investigate certain Users who have been determined to be risky or suspicious. Goldenlovi reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Goldenlovi reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past. User’s identification information will be collected, stored, shared and protected strictly in accordance with the Goldenlovi’s Privacy Policy and related regulations. Once the User’s identity has been verified, Goldenlovi is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

1.2. Card verification.
The Users who are intended to use payment cards in connection with the Goldenlovi’s Services have to pass card verification in accordance with instructions available on the Goldenlovi’s Site.

2. Monitoring Transactions.

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Goldenlovi relies on data analysis as a risk-assessment and suspicion detection tool. Goldenlovi performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

3. Risk Assessment.

Goldenlovi, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Goldenlovi is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.