DREAM Token Sale GFSC Compliant KYC and AML Process

DREAM Token Sale GFSC Compliant KYC and AML Process

A large part of planning a token sale is ensuring that financial regulation is closely followed and that as a token issuer, you know who your customers are and where the money they are contributing to the project has originated from.

As part of DREAM’s ongoing efforts to build a world class blockchain talent platform we will soon be running our token sale. As part of the setup process for the token sale, we incorporated our business in Gibraltar — one of the leading jurisdictions for ICO regulation and token sale best practices.

Working with the Gibraltan framework and with with significant work with our legal team and KYC partners, DREAM have designed and implemented a KYC and AML process that provides maximum security for our sale as well as a convenient and frictionless experience for token purchasers.

For those looking to purchase DREAM tokens and contribute to our project you will need to have your contributing ETH wallet address whitelisted to be able to make a contribution. To get a wallet whitelisted simply complete the information on the registration sale site and let us do the rest (more information will be provided in June 2018).

KYC Process

Our KYC process is being supported by Verif-y, who are specialists on automated KYC and who have a pedigree for working with ICOs. Their involvement in the process is fully integrated and token purchases will be presented with the Verif-y KYC interface as part as the whitelisting process on our website.

AML Process

We have a dedicated Money Laundering Reporting Officer (MLRO) based in Gibraltar that will review every transfer request after receiving the green light from the KYC process. The MLRO is also responsible for reviewing additional information as part of the Source of Funds checks and enhanced company due diligence.

The MLRO must be based in Gibraltar for all token sales.

Steps to Whitelisting

The white list process is as follows below:

  1. User Registration — User registers by entering their email and password on the https://tokensale.dream.ac website

  2. Two-Factor Authentication — User must configure Google Authenticator two-factor authentication before being able to proceed

  3. Set Ethereum Wallet — User must set their Ethereum wallet address before they can start the whitelist process

  4. Whitelist Phase #1 — Set Funding Level and Provide Source of Wealth. Funding level set and Source of Wealth information collected including employment status, job title, source of income (Eg; employer information), income per annum and source of wealth.

  5. Whitelist Phase #2 — User enters additional personal information, including; full name, email, uploads proof of current address (e.g. utility bill, driving licence), sets nationality and date of birth. User uploads scanned copy of passport or national ID, including photograph of ID with ID owner.

  6. Whitelist Phase #3 — Following a successful KYC check, Verif-y will send GREEN status to KYC checks to MLRO. The DREAM admin can check status in Verify SaaS dashboard if required.

  7. Review — The MLRO will review KYC and any additional documentation provided and make decision on whitelisting and maximum contribution amount.

  8. Smart Contract — Automated background worker / job on DREAM adds the Ethereum address to the smart contract and set the maximum contribution amount.

Institutional Contributors

For institutional contributors (contributors such as body corporates, trust etc) additional information will be collected as part of the process. This will include the following;

  • Full entity name;

  • Business address or principal place of business (if any);

  • Registered office (if any);

  • Registration number (if any);

  • Names of directors, trustees, councillors (as applicable);

  • Names of shareholders, settlers, founders, beneficiaries (as applicable);

  • Wallet address.

Source of Wealth

In some cases the MLRO will need additional information about the source of funds, additional Source of Wealth information may need to be provided as part of the KYC and AML process.


The MLRO will reach out to customers directly to obtain additional information. Source of Wealth documentation can include the following;

  • Source of Wealth — Relevant Supporting Documentation

  • Savings from Employment — Document showing salary, employer’s name and address, and nature of business (e.g. recent payslip, or letter from employer)

  • Sale of Investments — Document showing transaction (e.g. statement from investment provider or bank statement showing settlement from investment provider).

  • Sale of Property — Signed letter from professional participant (e.g. solicitor or Estate Agent), or sale contract.

  • Loan — Document showing name of the Loan provider, and date, amount and purpose of loan (e.g. loan agreement).

  • Inheritance — Document showing name of deceased, their relationship to the client, date of death and amount received (e.g. Grant of Probate or letter from solicitor).

  • Maturity or Surrender of Life Assurance Policy — Document showing name of policy provider, date of maturity or surrender, and amount received (e.g. closing statement, or letter from policy provider).

  • Sale of Company — Signed letter from professional participant (e.g. lawyer or accountant) or sale contract.

  • Profits from Company — Document showing name and address of company, nature of business, and annual profits (e.g. latest audited company accounts).

  • Divorce Settlement — Document showing name of ex-spouse, amount received and date of settlement (e.g. court order).

  • Other Court Award or Compensation — Document showing reason for award, amount received and date of award (e.g. Court Order).

  • Gift — Document showing who gave the gift, when and why (e.g. letter from donor), plus verification of identity of the donor, and information about the source of their wealth.

The MLRO will then review this information as part of the application and make a decision based on the evidence provided.


In cases involving institutional contributors where the MLRO required additional information to approve a wallet they will reach out directly to a contributing body and may request information such as;

  • The latest report and accounts (audited where applicable);

  • Memorandum & Articles of Association, trust deed, charter or other similar documents;

  • Applicable board resolutions or documents evidencing the trustee/councillor decision making process;

  • Certificate of incorporation/certificate of trade or equivalent;

  • Certificate of good-standing

As much relevant information will be collected throughout the registration for whitelist process on our website and should your wallet pass the KYC and MLRO assessment you will be automatically updated by email. Only if the MLRO needs additional information to approve the wallet will you be contacted directly.

Restricted Countries

Restrictions (citizens of what countries cannot participate)

  • Belarus

  • Burma

  • Cote D’Ivoire (Ivory Coast)

  • Cuba

  • Democratic Republic of Congo

  • Liberia

  • Macedonia

  • Moldova

  • Serbia

  • Sudan

  • Zimbabwe

  • China

  • United States

  • North Korea

  • Bosnia and Herzegovina

  • Ethiopia

  • Iraq

  • Iran

  • Sri Lanka

  • Syria

  • Trinidad and Tobago

  • Tunisia

  • Vanuatu

  • Yemen

Process Flow

Our entire whitelisting flow can be seen below.


We appreciate our customers willingness to share the required information with us as we will only collect necessary information to ensure compliance throughout the sale.


Certain statements in this article constitute ”forward looking statements” that are used on the beliefs of DREAM and reflect the company’s current expectations. Such statements reflect the views of DREAM at the time the statements are made with respect to future events based on information available at that time, and they are subject to risks and uncertainties that could cause actual results to differ materially from those contemplated in those forward-looking statements. DREAM assume no obligation to update or revise these statements to reflect current information, events or circumstances, including changes in any risks or uncertainties that may impact them

The purpose of this article is to provide prospective purchasers of DREAM tokens with information on DREAM project to allow these prospective purchasers to make their own decision as to whether or not it wishes to proceed to purchase DREAM tokens. This article is not intended to be an offer to sell, or a solicitation of any offer to buy, any security or other financial instrument. The offering of DREAM token has not been registered, qualified, or approved under any securities, futures, financial instruments, capital markets, or exchange control legislation, regulation, or ordinance of any jurisdiction.

The purchase of DREAM tokens is only possible after the prospective purchaser has read, understood and accepted the Terms for the DREAM token sale. Each prospective purchaser will be required to acknowledge that they have made an independent decision to purchase the DREAM tokens and that it is not relying, in any manner whatsoever, on the company, its board of directors, or any other person or entity (other than such purchaser’s own advisers).

The DREAM platform isn’t just another untested beta program on a white paper… It’s live and being used right now to hire blockchain professionals. The token sale will enable DREAM’s innovative team to take DREAM to the next level by integrating A.I. and incorporating our platform token.

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DREAM Token Sale GFSC Compliant KYC and AML Process
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