Legal & Policy Framework

These Terms & Conditions govern your access to and use of the MoonGate website, platform, and all coordination services provided by MoonGate Administrative & Commercial Services W.L.L ("MoonGate").

Scope of Services

MoonGate provides administrative and commercial coordination services only. By accessing this website or submitting any inquiry, you acknowledge that MoonGate is not a financial institution, investment advisor, legal counsel, escrow provider, or regulatory body.

• Use of this website constitutes acceptance of these terms
• Services are subject to full KYC/KYB coordination and written agreement
• MoonGate reserves the right to decline any engagement without explanation
• All coordination services are administrative in nature — no financial transactions are processed by MoonGate
• Users are responsible for their own legal, tax, and regulatory compliance
• These terms are governed by the laws of the State of Qatar

MoonGate collects and processes personal data strictly for the purpose of providing administrative coordination services. Data is handled in accordance with applicable Qatar data protection regulations.

Data We Collect

• Identity documents (passport, government ID) — for KYC/KYB coordination only
• Company registration and business documents — for KYB verification
• Contact information (name, email, phone) — for communication purposes
• Inquiry and transaction-related correspondence
• Website usage data (cookies, analytics) — see Cookie Policy

Data Usage

• Processing coordination inquiries and member applications
• Performing preliminary administrative document review
• Communicating service updates and coordination status
• Complying with applicable legal and regulatory obligations

Data Sharing

MoonGate does not sell personal data. Data may be shared with counterparties in a coordination engagement only after NCNDA execution and explicit party consent. Data may be disclosed to authorities when legally required.

MoonGate maintains an AML/CTF awareness framework as part of its compliance-oriented coordination process. All parties engaging with MoonGate are subject to preliminary administrative screening before any coordination activity.

Our AML/CTF Awareness Approach

• Preliminary identity and business document review for all parties
• Cross-referencing submitted documents against publicly available sanctions lists
• Declining engagements involving parties from high-risk jurisdictions
• Maintaining records of all coordination inquiries and submissions
• Refusing to facilitate transactions with apparent AML/CTF indicators

Important Limitations

MoonGate's AML/CTF awareness process is administrative and preliminary only. It does not replace formal AML/CTF compliance obligations of financial institutions, banks, or regulated entities involved in the same transaction. Each party remains independently responsible for their own AML/CTF compliance.

All parties wishing to engage with MoonGate's coordination services must submit required identity and business documents. This preliminary KYC/KYB coordination is a prerequisite for any commercial introduction or coordination activity.

Individual Requirements (KYC)

• Valid government-issued photo identification (passport or national ID)
• Proof of residential address (utility bill or bank statement — within 90 days)
• AML/KYC self-declaration form
• Source of funds statement (for relevant engagements)

Company Requirements (KYB)

• Certificate of incorporation / commercial registration
• Valid trade license
• Memorandum and articles of association
• Beneficial ownership disclosure (UBO declaration)
• Proof of registered business address
• Banking reference or corporate letter of good standing

Review Process

Submitted documents undergo a preliminary administrative review for completeness and consistency. MoonGate may request additional documentation at any stage. Preliminary KYC/KYB Coordination does not guarantee engagement acceptance.

Key Risks to Understand

• Counterparty Risk: MoonGate coordinates introductions only. We cannot guarantee the reliability, financial capacity, or legal status of any introduced counterparty.
• Documentation Risk: Commercial documents submitted through MoonGate are reviewed administratively only — not legally validated or authenticated.
• Commodity Risk: Prices, availability, quality, and regulatory requirements for commodities can change materially. See Commodity Trade Risk Notice.
• Jurisdictional Risk: Cross-border transactions are subject to the laws and regulations of multiple jurisdictions. Independent legal advice is essential.
• Fraud Risk: Despite preliminary screening, MoonGate cannot guarantee the legitimacy of all parties. Parties must conduct their own due diligence.
• Regulatory Risk: Applicable regulations may change. Parties are responsible for monitoring their own compliance obligations.

Engaging with MoonGate's coordination services does not reduce or transfer any of these risks to MoonGate. Final commercial decisions remain entirely with the parties involved.

MoonGate Administrative & Commercial Services W.L.L provides administrative and commercial coordination services only. The following explicit limitations apply to all MoonGate activities:

• MoonGate is not a licensed financial advisor or investment firm
• MoonGate is not a bank or regulated financial institution
• MoonGate is not an escrow provider or payment processor
• MoonGate is not a licensed legal advisor or law firm
• MoonGate is not a certified AML/CTF compliance authority
• MoonGate is not a regulator or government body
• MoonGate is not a guarantor of any commercial transaction
• MoonGate does not hold, manage, or transfer client funds
• MoonGate does not provide assurance on counterparty credibility

All website content is provided for informational purposes regarding MoonGate's administrative services only. Parties must obtain independent legal, financial, banking, and regulatory advice before engaging in any commercial activity.

MoonGate retains personal and business data collected during the coordination process in accordance with applicable Qatar law and operational requirements.

Retention Periods

• KYC/KYB documents: retained for a minimum of 5 years following last engagement
• Coordination correspondence: retained for 3 years following last communication
• Website inquiry records: retained for 2 years
• Completed coordination records: retained for 7 years (regulatory compliance)
• Cookie and analytics data: retained for 12 months

Data Deletion Requests

Parties may request deletion of their data subject to applicable legal retention requirements. Requests should be submitted to info@moongatecs.com. MoonGate will respond within 30 business days.

MoonGate applies a risk-based preliminary review process for all prospective coordination clients. Acceptance is not guaranteed and is subject to the completion of all required preliminary KYC/KYB coordination steps.

Acceptance Criteria

• Completion of preliminary KYC/KYB documentation submission
• No adverse findings in preliminary sanctions screening coordination
• Commercially viable inquiry within MoonGate's service scope
• Execution of NCNDA prior to any counterparty introduction
• Acceptance of MoonGate's Terms & Conditions and all applicable policies

Right to Decline

MoonGate reserves the right to decline any engagement at any stage, without providing reasons, without liability to the declined party. A decline does not constitute a finding of wrongdoing or non-compliance.

MoonGate applies a Sanctions Screening Coordination process as part of its preliminary administrative review. All parties are subject to this process before any coordination activity is undertaken.

Screening Coordination Approach

• Cross-referencing party names against publicly available sanctions lists (OFAC SDN, UN, EU consolidated)
• Screening of company names, beneficial owners, and key principals
• Reviewing party jurisdictions against high-risk country lists
• Documenting screening results for internal record-keeping

Zero Tolerance

MoonGate will immediately terminate any engagement where a party is found on or associated with sanctions lists. MoonGate will not facilitate any commercial coordination activity that may violate applicable sanctions regimes.

MoonGate uses cookies and similar tracking technologies to improve website functionality and user experience. By continuing to use this website, you consent to the use of cookies in accordance with this policy.

Types of Cookies Used

• Essential Cookies: Required for basic website functionality. Cannot be disabled.
• Analytics Cookies: Used to understand how visitors interact with the website (anonymised data only).
• Preference Cookies: Remember user settings and preferences.

Cookie Management

You can manage cookie preferences through your browser settings. Disabling non-essential cookies may affect website functionality. Cookie data is retained for up to 12 months. Contact info@moongatecs.com for cookie-related enquiries.

All commercial coordination introductions facilitated by MoonGate are protected under a Non-Circumvention, Non-Disclosure Agreement (NCNDA) executed prior to any counterparty introduction. Circumvention of MoonGate as the introducing coordinator is strictly prohibited.

Key Provisions

• All parties introduced through MoonGate must not bypass MoonGate for related transactions without written consent
• Confidential commercial information shared during coordination is subject to non-disclosure obligations
• Non-circumvention obligations apply for a minimum of 24 months from the date of introduction
• Where applicable, fee protection is governed by a separate IMFPA (Irrevocable Master Fee Protection Agreement)
• Breach of NCNDA obligations may result in legal action under applicable Qatar law

Parties engaging in commodity trade coordination through MoonGate must understand the following risks specific to commodity transactions:

Commodity-Specific Risks

• Price Volatility: Commodity prices fluctuate significantly due to market, geopolitical, weather, and supply/demand factors. MoonGate provides no price guarantees.
• Quality & Specification Risk: Physical commodity quality must be independently verified by accredited inspection bodies (SGS, Intertek, etc.). MoonGate does not verify physical product quality.
• Logistics & Delivery Risk: Shipping, insurance, and delivery arrangements are between buyer and seller. MoonGate does not arrange or guarantee logistics.
• Regulatory & Export/Import Risk: Commodity trade is subject to export controls, import regulations, sanctions, and customs requirements across multiple jurisdictions.
• Documentation Risk: Trade documents (SGS, Q88, BCL, SPA, POP) submitted through MoonGate are reviewed administratively only — not authenticated or legally validated.
• Counterparty Performance Risk: MoonGate cannot guarantee that any introduced buyer or seller will perform their contractual obligations.
• Gold Trade: All gold coordination follows LBMA-awareness principles. MoonGate does not certify gold provenance or LBMA compliance.

Parties must engage independent legal counsel, commodity specialists, logistics providers, inspection bodies, and financial institutions for all aspects of their commodity transactions. MoonGate's role is limited to preliminary administrative coordination only.