Anti-Money Laundering (AML) Policy

Goldealers Ltd operates as a high-value precious metals dealer with a strict cash-free business model. In compliance with the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017, businesses that do not accept cash payments are not required to register for supervision with HM Revenue and Customs (HMRC) for AML purposes.

Despite this exemption, Goldealers Ltd is dedicated to maintaining the highest standards of integrity and transparency. Our proactive AML policy mitigates the risk of our business being exploited for money laundering or terrorist financing.

2. Scope

This policy applies to all employees, directors, officers, and agents of Goldealers Ltd involved in the sale, purchase, or trade of precious metals across all business activities within the UK.

3. Key Definitions

  • Money Laundering: Concealing the origins of illegally obtained money through transactions or transfers.
  • Terrorist Financing: Providing financial support to individuals or groups involved in terrorism.
  • Supplier Due Diligence (SDD): Verifying the identity and risk levels of suppliers.
  • Customer Due Diligence (CDD): Verifying the identity and risk levels of customers.
  • Suspicious Activity Report (SAR): Reporting suspicious activity to the National Crime Agency (NCA).

4. Supplier Due Diligence (SDD)

Transaction Limits: Suppliers may sell up to £5,000 of precious metals with a single form of photo ID. For transactions exceeding £5,000, additional proof of address is required. If a driver’s license is used, a separate proof of address is mandatory.

For Companies: Verify the company name, registration number, registered address, and identities of directors and beneficial owners.

5. Customer Due Diligence (CDD)

Transaction Limits: Customers may purchase up to £5,000 of precious metals with a single form of photo ID. Transactions exceeding £5,000 require additional proof of address. If a driver’s license is used, a separate proof of address is mandatory.

For Companies: Verify the company name, registration number, registered address, and identities of directors and beneficial owners.

6. Risk Assessment

Risk-Based Approach: Evaluate each customer or supplier’s risk level based on factors such as background, geographical location, and transaction complexity.

Enhanced Due Diligence (EDD): Apply EDD for higher-risk individuals or entities, such as those involved in large or complex transactions.

7. Ongoing Monitoring

All customer and supplier transactions are continuously monitored for suspicious activity. Customer information is regularly updated, and CDD records are reviewed periodically.

8. Suspicious Activity Reporting

Employees must report suspicious activity immediately to the AML Compliance Officer. The Compliance Officer will investigate and, if necessary, submit a SAR to the NCA without delay.

9. Record Keeping

All records of CDD, transactions, and SARs are retained for at least five years. Records must be readily accessible for regulatory inspection.

10. Training and Awareness

Regular AML training is provided to all employees to ensure understanding of CDD processes, identifying suspicious activity, and reporting obligations.

11. Internal Controls and Audits

Robust internal controls are in place to ensure compliance. Regular audits assess the AML program’s effectiveness and identify areas for improvement.

12. Policy Review and Updates

This policy is reviewed annually or when regulatory or operational changes occur. The AML Compliance Officer is responsible for ensuring the policy remains up-to-date and effective.