GEMtrust DAO Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Last Updated 1 March 2026

At GEMtrust DAO, our commitment to financial integrity and regulatory compliance reflects the highest institutional standards. We are dedicated to actively combating money laundering, terrorist financing, and all other forms of illicit financial activity that could undermine the trust, security, and integrity of the broader financial ecosystem.

Gem DiCom is structured exclusively for qualified professional investors under applicable private placement frameworks. GEMtrust DAO operates in accordance with internationally recognized AML/CFT standards, including the recommendations of the Financial Action Task Force (FATF), and monitors regulatory developments across all relevant jurisdictions to ensure ongoing compliance alignment.

GEMtrust DAO maintains a dedicated compliance function responsible for the implementation, monitoring, and continuous review of this Policy. All compliance procedures are conducted by or under the supervision of qualified compliance professionals.

REGULATORY FRAMEWORK. GEMtrust DAO's AML/KYC framework is designed to meet or exceed the standards established by internationally recognized regulatory bodies, including the Financial Action Task Force (FATF) and applicable national financial intelligence units. Our compliance structure is maintained to accommodate regulatory requirements across multiple jurisdictions and is subject to ongoing review as regulatory frameworks evolve. 

JURISDICTIONAL SCOPE. Participation in Gem DiCom is restricted to qualified professional investors under applicable private placement standards. GEMtrust DAO reserves the right to apply additional compliance requirements in respect of participants from specific jurisdictions, in accordance with applicable law. Participants from jurisdictions subject to enhanced regulatory scrutiny may be required to satisfy supplementary eligibility and documentation requirements prior to admission.

To fulfill regulatory obligations and uphold standards, GEMtrust DAO has established formal collaborations with reputable, independently licensed third-party compliance service providers. These partners hold the necessary expertise, professional qualifications, and regulatory authorizations to manage critical aspects of our AML/KYC compliance framework.

Mandatory Know Your Customer (KYC) Verification. Identity verification is conducted for all participants, encompassing collection of requisite documentation – including government-issued identification and proof of domicile—and comprehensive due diligence procedures to confirm participant identity.
Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Compliance. Our compliance framework includes continuous transaction monitoring for suspicious patterns, identification and assessment of high-risk activities, and mandatory reporting of detected illicit financial movements to the appropriate regulatory authorities.
Institutional Record-Keeping & Audit Readiness. All collected data and transaction records are securely maintained and made accessible for regulatory audit purposes in full accordance with applicable legal requirements.
PEP & Sanctions Screening. All prospective participants are screened against applicable international sanctions lists, including the UN Security Council Consolidated List, EU Consolidated Sanctions List, and OFAC Specially Designated Nationals List. Participation is strictly prohibited for sanctioned individuals, entities, or jurisdictions. Politically Exposed Persons (PEPs) are subject to Enhanced Due Diligence procedures.
Enhanced Due Diligence (EDD). GEMtrust DAO applies Enhanced Due Diligence procedures to participants presenting elevated risk profiles, including but not limited to Politically Exposed Persons, participants from high-risk jurisdictions as designated by the FATF, or participants whose transaction profiles warrant additional review. EDD may require supplementary documentation, including source-of-wealth and source-of-funds verification.

By engaging with GEMtrust DAO and utilizing services that facilitate the acquisition of Gem DiCom, participants explicitly consent to the required identity verification and compliance procedures. These procedures are conducted by our licensed third-party compliance partners and constitute a mandatory condition of participation. Full cooperation with these processes is essential for maintaining a secure, transparent, and fully compliant environment for all eligible participants.

ACCESS RESTRICTION. Failure to successfully complete the required KYC verification procedures, or involvement in activities identified as suspicious, will result in the immediate restriction of access to Gem DiCom participation services. 

DATA PROTECTION. All personal data collected in the course of these procedures is handled with the utmost care and in strict accordance with the provisions of our Privacy Policy, ensuring that all applicable data protection rights are fully respected at all times.

Compliance Review Clause. This Policy is reviewed no less than annually and updated as necessary to reflect evolving regulatory requirements across applicable jurisdictions. GEMtrust DAO reserves the right to introduce additional compliance requirements in response to changes in applicable law or regulatory guidance.

Compliance Officer. GEMtrust DAO has designated a responsible compliance function for the implementation and oversight of this AML/KYC Policy. Compliance-related inquiries may be directed to our compliance Officer compliance@gemdicom.com