🏦 Anti-Money Laundering (AML) Policy of G-IT AG

This Anti-Money Laundering (AML) Policy applies to all employees of G-IT AG and all subsidiaries or affiliated companies providing services on behalf of G-IT AG. It outlines the framework for preventing money laundering, terrorist financing, and other financial crimes across all business operations, including the gingr.ch platform.

This policy is based on the Swiss Federal Law on Combating Money Laundering and Terrorist Financing in the Financial Sector (GwG), the FINMA Ordinance on the Prevention of Money Laundering (GwV-FINMA), and other international regulations applicable in G-IT AG’s jurisdictions.

Money laundering refers to the process of concealing the criminal origin of funds by integrating them into the legitimate financial system. This typically involves:

Predicate offences include, but are not limited to, drug trafficking, fraud, corruption, human trafficking, and tax evasion (recognized since 2016 in Switzerland).

Terrorist financing involves providing or collecting funds with the intent or knowledge that they will be used to support terrorist activities or organizations. These funds often stem from illegal activities and are transferred through various channels to evade detection.

All escorts must complete a Know Your Customer (KYC) process to use the gingr.ch platform.

For participation in the Prepaid Card by Gingr program, escorts are also required to submit a Proof of Address.

Both steps are handled via our certified third-party verification provider Dataspike.io.

Clients who wish to use the Pay on Invoice feature must complete a KYC verification and undergo an automated creditworthiness check performed through CRIF.

Partner companies undergo a detailed Know Your Business (KYB) process, which includes corporate document verification, beneficial ownership checks, and risk assessment.

Crypto top-ups on the gingr.ch platform are processed through Nowpayments, a trusted provider offering custody services for digital assets. All transactions are monitored and logged to ensure regulatory compliance, and the source of funds must be verifiable at all times.

The Board of Directors is responsible for ensuring the implementation and oversight of this AML Policy. Internal compliance is monitored through a defined Internal Control System (ICS).

G-IT AG maintains a dedicated AML Compliance function. Some specialized tasks, including enhanced due diligence and regulatory updates, may be handled by external partners.

A designated AML Compliance Officer (CLO) is responsible for suspicious activity monitoring, reporting to authorities, and employee training.

All platform transactions, including fiat and crypto, are continuously monitored using automated detection tools. The system applies a risk-based approach based on factors such as:

High-risk transactions are flagged and manually reviewed. Funds may be temporarily held or frozen pending further investigation.

It is strictly prohibited to:

Sanctions list screenings are applied automatically during onboarding and on an ongoing basis.

G-IT AG keeps records of all KYC/KYB verifications, transaction logs, and compliance reports in accordance with Swiss law. If a transaction or behavior appears suspicious, G-IT AG will submit a Suspicious Activity Report (SAR) to the Swiss Money Laundering Reporting Office (MROS).

All employees receive mandatory AML training. New hires must complete AML training before accessing any customer or transaction-related systems. The training covers current laws, red flags, reporting procedures, and platform-specific AML protocols.

Violations of this AML Policy may result in:

This AML Policy is effective as of July 30, 2024, and is subject to regular review and revision to reflect regulatory developments and business needs.