As a pioneering platform in digital asset trading, Gate has always prioritized the safety, stability, and reliability of its customers' experiences. The platform has established a comprehensive risk-based Anti-Money Laundering/Counter-Terrorism Financing/Sanctions (AML/CTF/Sanctions) program in line with international standards and practices, reflecting its commitment to fostering a secure environment for digital asset trading.
Gate's AML/CTF/Sanctions program represents a strong commitment to preventing money laundering, terrorist financing, and other illegal activities on the platform. This is achieved by implementing robust internal controls, including a set of AML/CTF/Sanctions regimes, standards, procedures, and other policy documents, all designed to create a risk-averse trading environment. In addition, Gate Group has already obtained licenses or registrations in many jurisdictions to provide digital asset-related services, including MSB/MTL in the United States of America, FINTRAC MSB in Canada, Proprietary Trading in Crypto-Commodities in DMCC, TCSP in Hong Kong, Virtual Currency Exchange Operator and Wallet Service Operator in Lithuania, Class 4 VFA Licence: Virtual Asset Exchange and Custodian Service in Malta, and Charity License in Gibraltar and more. It also proves to some extent that we have comprehensive risk-based Anti-Money Laundering/Counter-Terrorism Financing/Sanctions (AML/CTF/Sanctions) programs in line with international standards and practices.
Embracing KYC, CDD, and EDD Procedures
A key part of Gate’s anti-money laundering strategy revolves around Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) procedures. Gate has meticulously written KYC/CDD policies and procedures, and all customers must undergo KYC procedures before they begin trading.
This methodical approach to KYC involves different levels according to a risk-based approach. Customers are given different permissions through these levels based on a comprehensive evaluation of their risk profiles. And to enhance the KYC verification, Gate also cooperates with world-renowned identity authentication risk solution providers.
Ongoing Reviews and Global Sanctions Control
The platform also conducts ongoing reviews and monitoring of the customers’ transactions and profiles based on their risk ratings, with EDD implemented for higher-risk clients, and takes timely and necessary controls to mitigate risks. Gate maintains a stringent global sanctions review procedure with a real-time updated global sanctions database, a comprehensive transaction monitoring system integrated with well-known blockchain KYT solution providers for abnormal activities, and meticulous record-keeping practices. Together, these controls ensure that Gate does not engage with any sanctioned customer or customer beyond its risk tolerance.
Risk Management and Restricted Locations
Gate boasts a comprehensive risk management system. It has built a detailed risk control factor database and risk monitoring system, conducting real-time risk control inspections on its business operations. By closely monitoring various risk control indicators for early warnings and overruns, Gate ensures the asset security of the platform and its users, as well as a safe and healthy trading environment.
The platform also maintains a list of countries/regions where it does not provide services and implements stringent controls to intercept and manage potential risks in a timely manner.
Independent and Professional Risk Control & AML Team
Gate’s independent and professional risk control team is at the helm of these risk control measures and reports directly to the CEO. The team members hold relevant qualifications such as CAMS, CGSS, Certified Internal Auditor (CIA), etc., bringing many years of compliance and risk control experience in both traditional financial and crypto industries to the platform.
These measures are complemented by initial and continuing training for all related personnel, not only the Risk Control and AML team, but also all employees of Gate, ensuring every team member is equipped with up-to-date proper knowledge and skills to identify and mitigate potential risks in their positions.
Towards a Secure Cryptocurrency Future
Since its inception, Gate has taken a user-first approach, providing a secure and trustworthy digital asset trading environment. Through its comprehensive risk control measures and adherence to stringent AML/CTF/Sanctions standards, Gate is solidifying its position as one of the safest cryptocurrency exchanges in the world. This reflects Gate’s continuous commitment to staying ahead of the curve in compliance with applicable laws and regulations, protecting its users and the integrity of the digital asset industry.
Clarification on ZachXBT's Tweet
The situation described in ZachXBT's tweet is incomplete and partial, and we'd like to clarify:
1.Gate has implemented robust KYC controls and watchlist screening mechanisms through a leading provider of risk solutions in the industry. This strategic partnership enables us to conduct comprehensive initial screenings and ensure ongoing monitoring throughout the customer relationship. We would like to reiterate that our global watchlist screening encompasses authorities such as the Office of Foreign Assets Control (OFAC), the European Union (EU), the United Nations (UN), the Federal Bureau of Investigation (FBI), the Bureau of Industry and Security (BIS) and others. Furthermore, we continuously monitor media sources for any updates regarding sanctions and regularly test our name-screening vendors for any newly added blacklist to ensure the thoroughness and accuracy of our watchlists.
2.As a matter of fact, ZachXBT deliberately registered multiple fictitious accounts by inputting information of individuals who had recently been sanctioned by the OFAC or false names to test our KYC process. This approach was specifically designed to circumvent our robust KYC name screening controls.
Our name screening system has promptly detected a few unusual accounts (e.g. a true match against a recent OFAC target) registered by ZachXBT. Consequently, our system automatically triggered the requirement for ZachXBT to complete KYC2. As a result, his account underwent temporary restrictions, with limited functionality solely allowing the submission of KYC2 information. It is important to note that ZachXBT did not disclose this specific scenario on his Twitter.
After several rounds of testing by all means, it was revealed that ZachXBT intentionally entered Kim Jong-UN in the name field, while selecting the UK as both nationality and residence to bypass our vendor's back-end screening logic. As a consequence, our vendor's system flagged it as a false positive because the testing account 'Kim Jong-UN' associated with ZachXBT belongs to an individual with UK nationality and residence instead of North Korea.
3.Following the inadvertent passage of the fake testing account through the KYC1 level (while bearing in mind that certain products, transactions and withdrawal amounts remain restricted at this stage) our system subsequently detected anomalies and potential matches against the watchlist. Hence, in line with our risk-based approach, we swiftly took a series of further actions to address any concerns and mitigate potential risks. These actions included 1) communicating with our screening vendor for logic improvement 2) implementing immediate restrictions on the fictitious account, 3) expediting enhanced due diligence procedures to promptly request additional information, and 4) fine-tuning our name screening logic to adopt a more stringent approach.
4.In order to gain a better understanding of the KYC controls adopted by our industry peers, we have conducted rigorous and impartial testing of KYC controls implemented by other global leading crypto exchanges. During the assessment, we utilized the same keywords as ZachXBT’s including "Kim Jong-UN" to register testing accounts on four widely-used crypto exchanges. Note that the intention behind this testing was solely to evaluate the effectiveness and stringency of their KYC procedures in a standardized manner, without any bias or negative implications. Our findings revealed that, in the case of three out of four exchanges, the keyword of "Kim Jong-UN" was able to bypass the KYC1 requirement. Even in the instance of the remaining exchange enforcing mandatory KYC, our testing demonstrated that accounts could still be registered using the same keyword. Furthermore, we observed that certain exchanges provided deposit and withdrawal functionalities to customers even at the KYC0 level, which raised concerns regarding their adherence to rigorous security protocols. It is important to highlight that Gate, we prioritize the security and integrity of our services. Therefore, we have implemented mandatory KYC1 requirements for our customers, ensuring that they complete the necessary verification process to access our platform. This approach allows us to maintain a higher level of security while providing our users with a more controlled and secure environment.
5.Our dedicated team and robust internal systems have achieved a level of excellence through significant advancements and refinements. We are continuously committed to enhancing our AML/KYC controls to combat money laundering and terrorist financing effectively. Our tireless efforts are driven by our unwavering dedication to making Gate a safe and more secure platform for staying proactive and vigilant in evolving our security measures to provide you with the utmost protection and peace in mind.
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Gate Team
May 19th, 2023
