AML Policy

1. Purpose

The purpose of this AML Policy is to outline the framework GCBuying uses to prevent the platform from being used for money laundering, terrorism financing, fraud, or other illicit activities. GCBuying is committed to full compliance with the Money Laundering (Prohibition) Act, 2011 (as amended) and other applicable Nigerian and international regulations.

2. Scope

This policy applies to:

• All GCBuying employees and agents
• All users and account holders on the GCBuying platform
• All products and services offered by GCBuying including crypto and gift card transactions

3. Key Objectives

• Prevent GCBuying from being used for money laundering or terrorism financing
• Identify and mitigate risks associated with crypto and digital gift card transactions
• Ensure compliance with regulatory obligations and maintain the integrity of the platform

4. Customer Due Diligence (CDD)

GCBuying implements the following Know Your Customer (KYC) measures:

a. User Verification

• Full Name
• Email & Phone Number
• Valid Government-Issued ID (NIN, International Passport, Driver's License, etc.)
• Bank Account Information (must match user name)

b. Enhanced Due Diligence (EDD)

Applied in cases of:

• High-value transactions
• Suspicious user behavior
• Users from high-risk jurisdictions
• Transactions involving mixers or privacy coins

5. Monitoring & Reporting

GCBuying monitors user activity to detect suspicious behavior, including but not limited to:

• Rapid trades of large amounts
• Multiple accounts linked to one identity or IP

a. Suspicious Activity Reports (SARs)

• Flagged transactions are reviewed manually by the Compliance Officer
• Where necessary, SARs will be submitted to the relevant regulatory authorities such as the Nigerian Financial Intelligence Unit (NFIU)

6. Record Keeping

GCBuying maintains user transaction and identification records for a minimum of five (5) years after the last user interaction. These records include:

• KYC documentation
• Trade history
• System-generated activity logs
• SARs submitted and internal compliance reviews

7. Employee Training

All employees handling user data, funds, or compliance reviews receive AML training at onboarding and through periodic refreshers. Training covers red flags, KYC procedures, and escalation protocols.

8. Penalties for Non-Compliance

Users found engaging in suspicious or illicit activity will have their accounts frozen, investigated, and potentially reported to authorities. GCBuying reserves the right to suspend or ban any user in violation of AML protocols.

9. Review & Updates

This AML policy is reviewed annually and updated as necessary to reflect regulatory changes, technological updates, and evolving risk factors.