Anti-Money Laundering (AML) Policy

Effective Date: April 21, 2025

This AML Policy outlines the procedures and obligations of Gartle Limited ("Company") and its platform devcryptogate.com ("Platform") to ensure compliance with applicable anti-money laundering (AML) and counter-terrorism financing (CTF) requirements.

1. General Principles

The Company is committed to:

Preventing the use of its services for money laundering or terrorist financing.
Ensuring compliance with relevant regulations, including FATF standards and UN Security Council sanctions.
Implementing appropriate procedures for monitoring, detecting, and reporting suspicious activities.

The Company does not provide custodial services or engage in fiat currency transactions. All operations are conducted using cryptocurrencies.

2. Risk-Based Approach

The Company employs a risk-based approach to AML/CTF compliance:

Developers and their products are assessed for potential abuse.
Geographic risk is evaluated based on country of operation, domain data, and IP address.
Transactions are monitored based on size, frequency, and behavioral patterns.
High-risk behaviors are subject to enhanced due diligence or rejection.

The Company prohibits access to the Platform by individuals or entities from jurisdictions under UN sanctions.

3. Customer Verification (KYC)

All Developers must complete Know Your Customer (KYC) verification prior to offering products on the Platform. Requirements are described in detail in the KYC Policy.

Verification includes:

A business registration certificate or equivalent document.
A corporate email address matching the domain of the Developer's website.
Domain ownership confirmation (via DNS record, HTML file, or meta tag).
A bank-issued letter from a third party confirming the applicant's authority to access financial transaction information related to the registered business.
A document confirming the applicant’s authority to submit the application and manage the account.

In the case of suspicious activity or unusual transactions, additional verification may be required.

Buyers are not required to complete KYC unless necessary under specific AML scenarios. Email verification is mandatory for all purchases.

4. Transaction Monitoring

The Company monitors transactions on the Platform and may:

Screen wallet addresses against public sanction or blocklists.
Use third-party AML screening tools to assess transaction risk.
Detect behavioral patterns indicative of structuring, smurfing, or fraud.

Payments originating from or directed to wallets flagged by AML systems may be rejected or held for review.

Cryptocurrency addresses submitted by Developers for payouts are screened prior to approval.

5. Internal Controls and Training

The Company’s AML efforts are overseen by the General Director and designated compliance staff. Internal controls include:

Ongoing analysis of transactional activity.
Documentation and escalation of suspicious behavior.
Periodic audits of Developer behavior and platform usage.

All relevant personnel receive training on AML/CTF risks and red flags.

6. Reporting Suspicious Activity

Suspicious activities are reviewed and documented internally. Where required by applicable law, the Company may report such activities to the appropriate regulatory authorities.

Examples of red flags include:

Products priced significantly below market value.
Repeated refund requests shortly after purchase.
Mismatches between payment details and registration data.

7. Cooperation with Authorities

The Company cooperates with law enforcement and regulators as required by law. Requests must:

Be submitted in writing and provide sufficient context and specificity.
Include legal basis and the authority of the requesting entity.

8. Policy Review

This Policy is reviewed periodically and updated to reflect changes in regulation, industry best practices, and the Company’s internal procedures.