Centregold takes AML and KYC concerns very seriously. We have developed the following policy to establish identities of our customers and to prevent any possible money laundering activity. Centregold has established a variety of comprehensive verification and identification measures aimed at elimination of risks of system abuse.
1. The term "Company" refers to DU Digital Unity Ltd (Cyprus), Digital Unity Ltd (BVI), specifically to its website located at centregold.com, and its affiliates in Canada or overseas.
2. The term "Customer" refers to any individual or entity which registers with the Company.
II. Anti-Money Laundering Controls
1. The Company shall not deal with institutions that are not physically present in any country (shell institutions).
2. The Company shall not conduct transactions with non-established parties.
3. Suspicious Customer activity shall raise appropriate concerns and such Customers shall be asked additional questions, such as about the purpose of their transactions, whether they are currently travelling, and other relevant questions. The Company may decide to cease dealings with a Customer if no satisfactory explanation is received. The Company may also report suspicious activity to competent authorities if there are reasonable grounds to believe that a Customer poses significant risks or threats.
4. The Company shall make periodic assessments of its AML and KYC policies.
III. Know Your Customer Policy
1. The Company shall require identification of individuals or entities at the time of their registration with the Company. Namely, a registering individual is required to provide the following data: full name, residential address, telephone number, e-mail address, as well as optional data, such as the time zone and the best time to call. The Company shall take reasonable measures to review the registered information of the Customer.
2. The Company has established access to various databases identifying possible criminal or suspicious activity, such as credit card fraud.
3. The Company shall take reasonable measures to verify Customer information when a Customer places an order with the Company. This includes, but is not limited to, the following: ensuring that any data are not in any fraud database, that the name and address match the same, as listed in the Public or Private Telephone Directory, that the billing address matches the address in the Public or Private Telephone Directory, that the customer's order history does not raise any flags of suspicions. The Company takes a skilled approach to identify electronic records (such as IP address) of the Customer and compare them to any suspicious patterns.
4. Should there be any doubts as to the validity of the information provided by the Customer, the Company shall take additional steps to ensure that the Customer's information is valid and that the Customer does not pose significant risk of fraud or other risks. Additional measures include request of copies of identification documents from the Customer, such as their photo ID, utility bill, telephone bill, both sides of credit card, bank statement; asking additional questions in order to clarify some aspects of verification; sending physical letters to the Customer's residential address to confirm validity of the information provided; as well as using a third-party credit card order verification system.
5. An automated Customer account monitoring system shall be in place, and shall screen Customers' activity, such as log-ins and log-outs from the system, make queries of Customers' telephone numbers, query fraud databases, send alerts to the Company, to continuously ensure safety of the system and diminish fraud and other risks.
6. Customer names shall be checked against names of known or suspected terrorists or terrorist organizations, money launderers and other criminals.
7. Centregold has established access to a comprehensive database of suspected persons, to verify validity of customers' Photo IDs, such as passports and driver's licenses, and to establish whether or not the potential client is suspected of any crimes.