AML, KYC, AND FRAUD PREVENTION POLICY

Gili Jewels is committed to maintaining the highest standards of integrity, transparency, and security. This combined Anti-Money Laundering (AML), Know Your Customer (KYC), and Fraud Prevention Policy outlines the measures we take to prevent illicit activity, verify customer legitimacy, and protect both our business and our customers.

Although Gili Jewels is not a regulated financial institution, we voluntarily implement these protocols as part of our responsibility under U.S. law, including the Bank Secrecy Act (BSA), and as an industry best practice for jewelry businesses engaged in high-value transactions.

1. Purpose of This Policy

This combined compliance policy is designed to:

  • Prevent money laundering, terrorist financing, and fraudulent activity

  • Maintain transparent and legitimate business transactions

  • Verify customer identity where appropriate

  • Detect suspicious patterns associated with fraud or criminal activity

  • Fulfill reporting obligations, including Form 8300 for cash transactions over $10,000

  • Protect our customers and financial partners

  • Comply with applicable U.S. federal guidelines and industry best practices

2. Know Your Customer (KYC) Procedures

KYC procedures help us confirm the identity and legitimacy of customers in higher-risk situations. We may request additional customer information when:

  • Transactions are unusually large or inconsistent with typical retail activity

  • Billing and shipping details do not match

  • Multiple high-value orders are placed in a short period

  • Payment behavior appears irregular or suspicious

  • The order triggers internal or automated risk flags

Depending on the circumstances, verification may include:

  • Government-issued photo ID

  • Confirmation of billing address

  • Matching documentation for payment method

  • Additional contact information

If customers decline to provide verification when requested, Gili Jewels may cancel the transaction.

3. Customer Due Diligence (CDD)

Customer Due Diligence is applied for higher-value transactions or when red flags are identified. Measures may include:

  • Reviewing customer profiles and order history

  • Confirming consistency between payment and identity details

  • Verifying legitimacy of high-value transactions

  • Assessing whether multiple purchases appear related or structured

CDD is conducted to ensure transactions are not connected to illegal or fraudulent activity.

4. Monitoring and Detecting Suspicious Activity

Gili Jewels uses both automated fraud-filtering tools and manual review to detect potential risks. The following red flags may trigger enhanced review:

  • Multiple failed payment attempts

  • Sudden purchases of high-value jewelry by new or unverified customers

  • Mismatched billing and shipping addresses

  • Requests to ship to high-risk or unverified locations

  • Use of multiple credit cards or identities for related orders

  • Attempts to divide payments to avoid reporting thresholds

  • Unusual urgency or pressure to process an order

  • Orders inconsistent with normal consumer behavior

If suspicious activity is identified, Gili Jewels may:

  • Request additional verification

  • Cancel or delay the order

  • Restrict further purchases

  • Report the activity to appropriate authorities if required

5. Fraud Prevention Measures

To protect our customers and our business, Gili Jewels employs the following fraud prevention systems:

  • Automated fraud detection via Shopify and payment processors

  • Manual review of high-value or high-risk orders

  • IP and geolocation matching

  • Device fingerprinting tools

  • Chargeback monitoring

  • Verification emails, phone calls, or ID checks

  • Restrictions on mismatched or unverifiable payments

  • Cancellation of any transaction deemed suspicious or unsafe

We work closely with our payment processors to identify fraud patterns and prevent unauthorized transactions.

6. Cash Transaction Reporting (Form 8300)

U.S. federal law requires any business receiving more than $10,000 in cash or cash equivalents in a single or related transaction to file IRS/FinCEN Form 8300.

Cash equivalents include:

  • Money orders

  • Cashier’s checks

  • Traveler’s checks

If such a transaction occurs, Gili Jewels will:

  • Request customer identification

  • Collect required information

  • Complete and file Form 8300 within the legal timeframe

Customers will not be penalized for compliance but may not refuse required identification.

7. Recordkeeping Requirements

Gili Jewels maintains accurate records as required by law. Records may include:

  • Order details

  • Payment verification

  • Correspondence and documentation obtained during KYC/CDD

  • Fraud review summaries

  • Filed reports (such as Form 8300)

Records are stored securely and retained for the legally required period.

8. Internal Controls and Employee Training

To support ongoing compliance, Gili Jewels:

  • Trains staff involved in order review to recognize red flags

  • Reviews transactions that exceed certain value thresholds

  • Uses fraud-prevention tools integrated with Shopify and payment providers

  • Conducts periodic policy reviews

  • Maintains escalation procedures for suspicious cases

  • Updates systems and processes in response to emerging risks

9. Cooperation With Law Enforcement and Financial Institutions

Gili Jewels complies with lawful requests from:

  • FinCEN

  • IRS

  • Federal and state law enforcement agencies

  • Banks and payment processors

We do not notify customers when suspicious activity is reported, consistent with U.S. regulations.

10. Policy Review and Updates

This combined AML, KYC, and Fraud Prevention Policy is reviewed periodically and updated as needed to reflect:

  • Changes in law

  • Updated industry standards

  • Internal risk assessments

  • Operational improvements

Gili Jewels remains committed to maintaining a strong and effective compliance framework.

11. Contact Information

For questions regarding this policy, please contact us:

Email: support@gilijewels.com
Address:
Gili Jewels
98 Cuttermill Road, Suite 211N
Great Neck Plaza NY 11021
United States