Customer Due Diligence Procedure

Enkisonics Pty Ltd (ABN 48 688 943 106)

Trading as GunGov - Australia-wide Firearms Club & Compliance System

KYB, KYC, and Mandatory Weapons-Licensing Verification – Controlled Onboarding Flow

Version: 1.1 | Effective Date: November 2025 | Last Updated: November 2025

IMPORTANT NOTICE: This document outlines GunGov's comprehensive Customer Due Diligence (CDD) procedures for club onboarding and member verification in compliance with Australian firearms legislation, AML requirements, and fraud prevention standards.

1. Purpose & Regulatory Overview

This document outlines the Customer Due Diligence (CDD) procedures used by GunGov during the onboarding of:

• Shooting clubs (KYB and Weapons Licensing verification)
• Club officials (identity, authority, and role validation)
• Members (KYC depending on how they transact)

GunGov operates within a highly controlled and regulated industry. To protect the firearms ecosystem and satisfy regulatory expectations (including AML and fraud prevention requirements), GunGov does not allow any self-registration of clubs.

All clubs must be onboarded by invitation only, through direct engagement with GunGov staff.

2. Controlled Onboarding Process (Invitation-Only)

GunGov does not allow the public to create or register a club. All onboarding must be initiated internally as follows:

2.1 Contact and Verification of Intent

1. A club contacts GunGov (or GunGov receives a referral)
2. Rob (or an assigned GunGov officer) performs an initial pre-screening call:
   • Verifies the identity of the club representative
   • Confirms the club is active and recognised
   • Confirms they hold valid Weapons Licensing approvals (Range Approval and Club Approval)

This step blocks fraudulent or unauthorised entities immediately.

2.2 Controlled Invite Link Issuance

Once the preliminary check is complete:

• Rob requests Jarvis to generate a unique, single-use onboarding link for that specific club
• This link is sent only to the verified club representative (via email or SMS)
• The link expires if:
  • It is not used within a defined timeframe
  • It is accessed from unexpected locations or multiple unknown devices
  • Jarvis detects unusual access patterns or abuse

This ensures the onboarding flow cannot be accessed by the general public.

3. Mandatory KYB Document Verification (Precondition to Onboarding)

The onboarding link opens directly into Jarvis; however, no onboarding fields appear until two mandatory documents are uploaded:

1. Range Approval Certificate (issued by the relevant state Weapons Licensing branch)
2. Club Approval Certificate or Club Affiliation/Approval document

Jarvis will not proceed or unlock the rest of the onboarding process until both documents are supplied. These documents are the foundation of the CDD process.

4. Document Parsing, Authenticity Verification, and Weapons Licensing Cross-Checks

Once the documents are uploaded, GunGov performs several validation steps.

4.1 AI Document Parsing

Jarvis automatically extracts structured data from the Range Approval and Club Approval, including:

• Range name and location
• Approval and permit numbers
• Approval category and conditions
• Expiry dates
• Disciplines authorised
• Signatories and issuing authority details
• Government headers, seals, and metadata

4.2 Authenticity Checks

GunGov performs authenticity checks such as:

• Comparing the uploaded documents against known Weapons Licensing templates and formats
• Verifying the presence and plausibility of signatures, QR codes, and watermarks
• Checking expiry dates to ensure current validity
• Checking for signs of editing, tampering, or inconsistent metadata

Any abnormality results in an automatic compliance review and potential rejection or request for additional documentation.

4.3 Weapons Licensing Structure Verification

Information in the documents is cross-checked against state-specific requirements, such as:

• Required wording and headings for Range and Club Approvals
• Page count completeness and annexures
• Document type and structure specific to each jurisdiction (for example, QLD Weapons Licensing, NSW Firearms Registry, etc.)

The system ensures that the approvals appear genuine, current, and properly issued.

5. Full KYB Data Collection and Validation

Once the approvals pass initial validation, Jarvis begins the structured onboarding process.

5.1 Business and Club Data Collection

The following information is collected and stored:

• ABN (automatically cross-checked with ABR and ASIC)
• Legal business name
• Club trading name
• Registered address and postal address
• Range address details
• Operating hours
• Primary contact details
• Secondary and emergency contacts
• Website and social media links (used as additional identity signals)
• Approximate membership numbers and growth expectations
• Insurance details where applicable

5.2 Officials and Governance Roles

For each key governance and operational role, GunGov collects details such as:

• President
• Secretary
• Treasurer
• Safety Officer
• Range Officers
• Additional committee members

For each official, GunGov records:

• Full legal name
• Email address and mobile phone number
• Identity verification status (KYC where required, particularly if they have financial or administrative access)
• Confirmation that their role aligns with the approvals and club governance structure

This information is used to ensure that individuals with control and authority are legitimate and properly linked to the club and its approvals.

6. GunGov Representative-Assisted Onboarding

Every club is onboarded with direct human oversight to ensure accuracy, completeness, and compliance.

A dedicated GunGov representative (Rob or another trained compliance officer):

• Walks the club representative through each step of the onboarding process
• Confirms that the Range Approval and Club Approval documents match the details entered
• Ensures official roles and contact details are correctly entered and verified
• Reviews disciplines, range information, and opening hours against the approvals
• Explains ongoing obligations regarding member management, licence compliance, and updates

This hand-held onboarding approach significantly reduces the risk of fraud, misrepresentation, or data entry errors, and forms part of the formal CDD record for that club.

The general public has no access to this onboarding flow. Creating a club on GunGov always requires direct contact with GunGov and a controlled, invitation-only setup process.

7. Backend Compliance Review and Activation

After Jarvis and the GunGov representative have completed data capture and document checks, a formal compliance review is conducted.

The system compiles a compliance packet that includes:

• Copies of the Range Approval and Club Approval documents
• AI-extracted structured data from both documents
• ABN and business verification results
• Details of club officials and their roles
• Range and discipline mapping linked to the approvals
• Internal notes and logs from the representative-assisted onboarding session

GunGov compliance officers must then review and approve this packet.

A club cannot go live on GunGov until:

• Both approvals are verified and current
• KYB checks on the club and entity match the documentation
• The governance structure and officials have been validated
• The compliance team has explicitly approved activation

8. Member KYC Policy

GunGov's approach to KYC for members depends on how members interact with the platform.

8.1 Scenario A: Members Transact Directly via GunGov

Where members are paying membership fees or other charges directly through the GunGov platform, GunGov performs KYC in line with AML and payment provider requirements. This may include:

• Full name
• Date of birth
• Residential address
• Verification of identity documents where required
• Cardholder and payer verification

8.2 Scenario B: Members Do Not Directly Onboard to GunGov

Where members are managed by the club, and the club remains the primary interface with the member (for example, if payments are taken by the club directly), GunGov does not duplicate the identity checks.

Instead, as part of the club CDD file, GunGov obtains written assurance that the club:

• Verifies each member's identity in compliance with applicable requirements
• Verifies each member's firearms licence and eligibility
• Maintains an up-to-date membership register that is available to Weapons Licensing inspectors
• Will notify GunGov if a member becomes ineligible or has their licence suspended or cancelled

This provides assurance to payment partners and regulators that members are subject to appropriate identity controls, either directly by GunGov or via the club under regulatory obligations.

9. Ongoing Monitoring and Enforcement

GunGov continues to monitor clubs and approvals after onboarding.

9.1 Document Expiry Monitoring

• Range and Club Approval documents are tracked for expiry
• Clubs receive advance reminders prior to expiry
• If updated approvals are not provided, the club's access may be restricted or suspended until renewed documents are received and verified

9.2 Range and Discipline Updates

• Changes to ranges, disciplines, or operating conditions require updated documentation
• Significant changes trigger a mini-onboarding review and may require reapproval by compliance

9.3 Transaction Monitoring

• Payment behaviour that is inconsistent with the club's profile or licensing status may be flagged
• Unusual transaction patterns can lead to further review or enhanced due diligence

9.4 Audit Logs and Reporting

• All uploads, changes, approvals, and onboarding actions are logged with timestamps and user IDs
• These logs support internal audit, incident review, and regulator or partner inquiries

10. Fraud Prevention and System Integrity

GunGov's design and operational procedures ensure that the platform cannot be used to onboard fake or unauthorised clubs.

Key safeguards include:

• Invitation-only onboarding initiated by a GunGov representative
• Mandatory upload and verification of Range and Club Approval documents before any data collection
• AI-based parsing and comparison of approvals against known government formats
• ABN and business status verification against official registers
• Representative-assisted onboarding, with all clubs hand-held through setup
• Manual compliance review and approval prior to activation
• Continuous monitoring of document validity and transactional behaviour

Together, these controls create a strict and robust KYB framework that substantially reduces the risk of fraud, misrepresentation, or unauthorised access.

11. Summary for Payment and Compliance Partners

This CDD procedure demonstrates that:

• Club identity and legitimacy are verified using government-issued Range and Club Approvals
• No self-service or public path exists to create a club on GunGov; all onboarding is controlled and invitation-only
• Business identity is validated using ABN and official registers
• Club officials and governance roles are identified and verified
• Members are either KYC-verified directly by GunGov or subject to documented assurance from the club under regulatory obligations
• All onboarding and ongoing changes are logged, monitored, and subject to compliance oversight

This framework is designed to meet or exceed the expectations of payment providers and regulators for AML, fraud prevention, and customer due diligence in a highly regulated firearms environment.

Contact Information

For questions about our Customer Due Diligence procedures, please contact us:

Version: 1.1 | Effective Date: November 2025 | Last Updated: November 2025

This Customer Due Diligence Procedure complies with Australian AML/CTF legislation, payment industry standards, and firearms regulatory requirements.