AML / CTF Policy

MoonGate acknowledges that as a commercial coordinator operating in cross-border commodity trade, it operates in a sector with inherent financial crime risks. This policy establishes the framework for managing those risks in a proportionate, risk-based manner consistent with applicable Qatari law and international standards.

This policy applies to:

• All members, clients, counterparties, and mandated parties engaging with MoonGate
• All commercial coordination activities, deal introductions, and document facilitation services
• All staff, administrators, and agents acting on behalf of MoonGate
• All transactions and communications processed through the Platform

MoonGate does not provide banking services, hold client funds, or execute financial transfers. However, it recognises its role as a commercial coordinator may create indirect exposure to financial crime risk and takes a proactive approach to mitigation.

MoonGate applies a risk-based approach to AML/CTF compliance, assessing risk factors including:

• Country risk: Jurisdictions subject to FATF advisories, EU/UN/US sanctions, or high corruption indices
• Customer risk: PEPs, complex ownership structures, opaque beneficial ownership
• Product/service risk: High-value commodity transactions, particularly gold and petroleum
• Transaction risk: Unusual payment structures, cash requests, or undocumented fund flows
• Channel risk: Introductions from high-risk intermediaries or jurisdictions

Higher-risk scenarios require Enhanced Due Diligence (EDD). Lower-risk scenarios may qualify for Simplified Due Diligence (SDD) at MoonGate's discretion.

Before engaging in material commercial coordination, MoonGate collects and reviews KYC/KYB documentation sufficient to:

• Identify and verify the legal identity of the client or counterparty
• Understand the nature and purpose of the commercial relationship
• Identify beneficial owners holding 25% or more of the relevant entity
• Assess source of funds and source of wealth where relevant
• Confirm authority and mandate of representatives

MoonGate coordinates basic screening of parties against relevant sanctions lists including OFAC SDN, UN Security Council, EU sanctions registers, UK HM Treasury, and relevant GCC/Qatari watchlists.

MoonGate maintains internal procedures for identifying and escalating suspicious activity, including requests for unusual payment structures, inability to provide KYC/KYB documentation, inconsistencies in business purpose, transactions involving sanctioned jurisdictions, pressure to proceed without documentation, and unverifiable commodity volume claims.

Where suspicious activity is identified, MoonGate will escalate internally and may suspend or terminate engagement. MoonGate will not tip off any party subject to an internal escalation or regulatory referral.

MoonGate retains AML/CTF-relevant records for a minimum of five years from the date of the last transaction or the end of the business relationship, whichever is later. Records include KYC/KYB documentation, sanctions screening results, risk assessment outputs, suspicious activity reports, and transaction coordination records.

MoonGate's administrative team receives appropriate guidance on AML/CTF obligations, red flag recognition, and internal escalation procedures. Responsibility for AML/CTF compliance rests with MoonGate's senior management, which reviews this policy periodically and ensures it remains current with applicable law.