COMPLIANCE POLICY

Last updated: May 23, 2026

INTRODUCTION

At GoMining, maintaining strong compliance standards and preventing financial crime are top priorities. This Compliance Policy outlines the measures and procedures designed to combat money laundering, terrorist financing, fraud, and sanctions violations.

The Company operates in accordance with the laws and regulatory requirements of the British Virgin Islands, including applicable Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) regulations. In addition, the Company voluntarily aligns its compliance practices with international standards established by the Financial Action Task Force (FATF) and relevant U.S. sanctions frameworks.

The Company maintains a strict zero-tolerance approach toward illegal financial activity. All personnel are expected to remain vigilant, follow internal compliance procedures, and immediately report any suspicious activity to the designated Compliance Officer (CO).

SCOPE OF THIS POLICY

This Policy applies to all employees, officers, directors, consultants, contractors, and individuals acting on behalf of the Company.

All personnel are required to:

  • Read and understand this Policy
  • Follow all compliance procedures
  • Cooperate with internal investigations and regulatory requests
  • Acknowledge compliance responsibilities within the required timeframe

Failure to comply with this Policy may result in disciplinary action, termination of employment or contracts, and potential civil or criminal liability.

CUSTOMER DUE DILIGENCE (CDD)

Before establishing a business relationship, all clients must complete Customer Due Diligence (CDD) procedures.

Required information may include:

  • Full legal name
  • Date and place of birth
  • Government-issued photo identification
  • Selfie or identity verification
  • Proof of residential or business address issued within the last 3 months
  • Citizenship information
  • Valid email address and contact details

For corporate entities, incorporation documents and beneficial ownership information may also be required.

The Company follows a risk-based compliance approach. Additional verification measures may apply to users identified as higher risk.

ENHANCED DUE DILIGENCE (EDD)

Enhanced Due Diligence procedures may be applied in situations involving:

  • High-risk jurisdictions
  • Politically Exposed Persons (PEPs)
  • Complex ownership structures
  • Unusual transaction patterns
  • Suspicious screening results

EDD procedures may include:

  • Senior management approval
  • Verification of the source of funds
  • Enhanced transaction monitoring
  • Additional identity documentation

The Company reserves the right to reject or terminate relationships that present unacceptable compliance risks.

PROHIBITED JURISDICTIONS

The Company does not provide services to individuals or entities located in, incorporated in, or associated with jurisdictions subject to comprehensive sanctions or restrictions.

Restricted jurisdictions currently include:

  • Afghanistan
  • Cuba
  • Iran
  • Myanmar
  • North Korea
  • Somalia
  • South Sudan
  • Syria
  • Yemen
  • Crimea region of Ukraine
  • Donetsk People’s Republic (DNR)
  • Luhansk People’s Republic (LNR)

Compliance controls may include IP geolocation screening, identity verification procedures, blockchain analytics tools, and sanctions monitoring systems.

SANCTIONS COMPLIANCE

The Company complies with applicable sanctions laws and regulatory requirements, including British Virgin Islands regulations and applicable international sanctions frameworks.

Transactions involving sanctioned individuals, entities, or restricted parties are strictly prohibited.

Employees and representatives must not engage with:

  • Individuals listed on sanctions watchlists
  • Restricted organizations
  • Entities owned or controlled by sanctioned persons

Any digital assets associated with blocked or restricted activity may be frozen or held in secure storage pending regulatory review.

TRANSACTION MONITORING

The Company continuously monitors customer activity to identify suspicious or unusual transactions.

Employees are required to report activities that may include:

  • Large or unexplained transactions
  • Activity involving high-risk jurisdictions
  • Structuring or attempts to avoid reporting thresholds
  • Transactions inconsistent with a client’s known profile
  • Complex transfers with no clear business purpose

Examples of review thresholds may include:

  • Transactions above $10,000 individually
  • Aggregate activity above $50,000 within 14 days
  • Aggregate activity above $100,000 within 30 days

Employees must not disclose internal investigations or suspicions to customers or unauthorized parties. Unauthorized disclosure (“tipping off”) may violate applicable laws.

RECORD RETENTION

The Company maintains records in accordance with applicable legal and regulatory requirements.

Retention periods may include:

  • Customer Due Diligence records: minimum 7 years
  • Transaction records: minimum 5 years after completion

Records must remain secure, accessible, and available for regulatory review when required.

COMPLIANCE TRAINING

All employees and relevant personnel must complete AML/CFT compliance training on a regular basis.

Training programs may include:

  • Anti-money laundering procedures
  • Sanctions awareness
  • Fraud prevention
  • Suspicious activity reporting
  • Regulatory updates

The Compliance Officer is responsible for maintaining training records and evaluating the effectiveness of compliance programs.

REGULATORY REQUESTS

If any employee receives communication from a regulator, government authority, or law enforcement agency, they must:

  • Immediately notify the Compliance Officer
  • Avoid independent responses or unauthorized discussions
  • Forward all documentation and requests internally

Only authorized personnel may respond to regulatory inquiries on behalf of the Company.

REPORTING VIOLATIONS

All employees and contractors are encouraged to report known or suspected violations of this Policy in good faith.

The Company maintains a strict non-retaliation policy for individuals who report concerns honestly and responsibly.

POLICY REVIEW

This Compliance Policy is reviewed periodically and updated as necessary to reflect:

  • Regulatory developments
  • Industry best practices
  • Internal risk assessments
  • Operational or legal changes

The Company reserves the right to amend this Policy at any time without prior notice.

CONTACT INFORMATION

For compliance-related questions or concerns, please contact:

Compliance Officer Email: contact@gominign.com