KYC / AML Policy

Last revised: April 2026

GM Data Centers AG maintains comprehensive procedures against money laundering (AML) and for customer identification (KYC). The company explicitly prohibits money laundering and terrorist financing and implements all applicable laws and regulations.

1. AML Compliance Officer

Green Mining designates an AML Compliance Officer with full responsibility for the program, including monitoring obligations, employee training, record maintenance, and Suspicious Activity Report (SAR) filing.

2. Required Customer Information

For natural persons, we collect:

Full name · Date of birth · Residential/business address · Government-issued photo ID · Contact details

For legal entities, additionally:

Statutory documents · Description of corporate structure · Information on beneficial owners and core management

3. Verification Procedures

Identity verification uses documentary methods (unexpired government-issued photo ID plus proof of address) and, where applicable, non-documentary methods. For legal entities, individuals holding 25%+ equity or significant control must be identified.

4. Politically and Commercially Exposed Persons (PEP/CEP)

PEPs and CEPs are subject to enhanced due diligence. Additional documentation may be requested from the person's bank or financial institution.

5. Risk Indicators (Red Flags)

The following circumstances trigger enhanced review:

• Insufficient identity documentation
• Reluctance to disclose information
• Unusual or unexplained source of funds
• High account activity without a plausible economic rationale
• Law enforcement inquiries

6. Suspicious Activity Reports

SARs must be filed within 30 calendar days of initial suspicious activity detection (extendable to 60 days). Related documentation is retained for 5 years.

7. Retention Periods

Customer records are retained for 5 years after account closure. Verification records are kept for 5 years from the date of creation.

8. Training

All staff receive annual training covering: red flag identification, escalation procedures, record retention requirements, and consequences for non-compliance.

9. Contact

For questions about our KYC/AML policies: [email protected]