Parts of the GDF Code Referencing Sanctions
The GDF Code of Conduct is designed to establish a common understanding of the best practices and governance policies for the global digital asset market.
Divided into 10 parts, the Code addresses each component of the digital finance value chain, and is written from the perspective of general global regulatory frameworks. The following is a summary of where and how sanctions are covered throughout the Code.
Part I: OVERARCHING PRINCIPLES
2.c: We will put in place know-your-customer (KYC), customer due diligence (CDD), transaction monitoring and other AML/CTF processes commensurate with the nature, complexity and size of our business in order to deter, detect and report financial crime as defined in laws applicable to us, which may include laws on money laundering, terrorist financing, bribery and corruption, sanctions breaches, tax evasion and modern slavery.
Part III: PRINCIPLES FOR TOKEN PLATFORMS
5d. We will take necessary actions, including technical solutions and surveillance, to prevent, detect, or deter money-laundering, terrorist financing or sanctions risk.
Part IV: PRINCIPLES FOR FUNDS AND FUND MANAGERS
5.a: In keeping with the legal and regulatory requirements and the Overarching Principles, we will conduct know-your-customer due diligence on all our investors with a view towards identifying, detecting or deterring non-compliance with anti-money laundering, counter-terrorist financing, sanctions and anti-bribery laws.
Part VII: PRINCIPLES FOR SECURITY TOKEN OFFERINGS AND SECONDARY MARKET TRADING PLATFORMS
1.f.: In the event that a Security Token offering is only available to a limited circle of investors in a particular jurisdiction, and where it makes sense, we will take reasonable steps to:
1.f.ii: Limit the jurisdiction(s) from which an investor may purchase/seller may market the token, jurisdictions where: sanctions apply, the EU has designated it as a high risk third country; and legislation where no recognised legal / regulatory framework for Security Token applied;
7.d: Our KYC and AML checks will include applicable sanctions list checks and due-diligence. We will also carry out screening on ultimate beneficial owners.
7.e: When onboarding potential investors, we will aim to understand their business activity, the goods they are trading and the countries in which they are located to avoid facilitating sanctioned transactions and enable assessment of whether those activities implicate applicable sanctions laws
7.f: We will not carry out or facilitate any transactions which would contravene applicable sanctions laws, or with any embargoed or sanctioned countries, or persons from those countries.
Part VIII: PRINCIPLES FOR KYC/AML
6.e: We will take appropriate measures to identify customers subject to economic sanctions, or who may be politically exposed persons (PEP), or those who pose a higher risk of ML / TF.
6.k: We will take appropriate measures to ensure that we do not onboard or transact with any party where to do so would be in breach of sanctions imposed by the United Nations or any jurisdiction with whom our firm has a nexus.
7.a: We will take appropriate measures, using a risk-based approach, to periodically review our customers and identify those subject to economic sanctions, who may be PEPs, or those who pose a higher risk of ML / TF.
7.c: We will conduct transaction monitoring on all transactions, whether fiat or virtual asset, to detect unusual behaviour that may be indicative of money laundering or terrorist financing, or that may violate economic sanctions measures.
Part IX: PRINCIPLES FOR CUSTODY CUSTODIAL WALLETS
3.i: We will take necessary actions, including technical solutions and surveillance, to prevent, detect or deter moneylaundering, terrorist financing or sanctions risk, in accordance with the GDF Code of Conduct for KYC / AML.
