Anti-Money Laundering and KYC Policy

Our headquarters operates under the United Arab Emirates anti-money-laundering and counter-terrorist-financing framework (Federal Decree-Law No. 20 of 2018 and its implementing regulations). Dealers in precious metals and stones are designated non-financial businesses under that framework and report through the UAE Financial Intelligence Unit's goAML system. Our South African office observes the Financial Intelligence Centre Act where it applies.

Before any introduction, offer or contract we identify and verify every counterparty:

• The legal entity: registration documents, directors, registered address and licences.
• Ultimate beneficial owners: every natural person who owns or controls 25% or more, or otherwise exercises control.
• Authorised signatories and the individuals we deal with.
• The nature and purpose of the business relationship and the source of funds for the transaction.

We apply enhanced checks for politically exposed persons, state-owned entities, gold, diamonds, cash-intensive businesses, complex ownership structures and material from conflict-affected or high-risk areas. Senior management approves every enhanced-risk relationship.

Counterparties, owners and directors are screened against United Nations, UAE, EU, UK and US sanctions lists and against adverse media before onboarding, whenever lists change, and before each transaction.

• Accept cash payments for minerals or metals.
• Pay or receive funds through third parties who are not party to the contract.
• Deal with anonymous counterparties, shell companies without a business purpose, or anyone who refuses to disclose beneficial ownership.
• Ask a buyer for advance fees to release documents, cargo or introductions.

Staff report suspicions to the compliance officer, who files suspicious-transaction reports with the relevant authority. We do not tip off the subject of a report. KYC and transaction records are kept for at least five years after the relationship ends.