AML/KYC Policy

Last updated: March 2026

Good Invest Limited is committed to preventing the use of its platform for money laundering, terrorist financing, or other illicit activities. This policy outlines our Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures in compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) of Hong Kong and international best practices.

1. Customer Identification

1.1 Individual Clients

All individual clients must provide:

• Full legal name, date of birth, and nationality
• Residential address
• Government-issued photo identification (passport, national ID card, or driver’s license)
• Proof of address (utility bill, bank statement, or government correspondence issued within the last 3 months)

1.2 Corporate Clients

Corporate clients must additionally provide:

• Certificate of incorporation and constitutional documents
• Register of directors and shareholders (identifying ultimate beneficial owners with 25%+ ownership)
• Board resolution authorizing the account opening
• Identification documents for all directors and authorized signatories

2. Verification Process

Documents are verified using a combination of automated identity verification technology and manual review by our compliance team. Accounts are not activated until verification is successfully completed. In cases where additional information is required, our compliance team will contact you directly.

3. Risk Assessment

Each client is assigned a risk rating based on:

• Country of residence and nationality (against FATF and internal risk lists)
• Source of funds and source of wealth
• Nature and expected volume of transactions
• Politically Exposed Person (PEP) status

High-risk clients are subject to Enhanced Due Diligence (EDD), which may include additional documentation requirements, more frequent monitoring, and senior management approval.

4. Ongoing Monitoring

• Automated transaction monitoring for unusual patterns or suspicious activity
• Periodic re-verification of client information (annually for high-risk, every 3 years for standard)
• Screening against international sanctions lists (UN, EU, OFAC, HKMA) in real time
• Monitoring for changes in client risk profile

5. Suspicious Activity Reporting

If our systems or staff identify transactions or behavior that may indicate money laundering, terrorist financing, or other financial crime, we are obligated to file a Suspicious Transaction Report (STR) with the Joint Financial Intelligence Unit (JFIU) of Hong Kong. Good Invest is prohibited by law from informing the client that such a report has been made.

6. Record Keeping

In accordance with regulatory requirements, we retain all client identification records, transaction data, and compliance documentation for a minimum of 7 years after the termination of the business relationship or the completion of the transaction, whichever is later.

7. Staff Training

All Good Invest employees receive mandatory AML/KYC training upon hiring and annual refresher training thereafter. Our compliance team receives specialized advanced training on emerging financial crime typologies and regulatory developments.

8. Compliance Officer

Good Invest has appointed a dedicated Money Laundering Reporting Officer (MLRO) responsible for overseeing all AML/KYC activities, maintaining policies and procedures, and serving as the primary point of contact for regulatory authorities.

Contact: compliance@goodinvest.hk