Anti-Money Laundering (AML) Policy

This policy outlines Goldealers Ltd‘s commitment to preventing money laundering, terrorist financing, and proliferation financing. Goldealers Ltd is a business that trades in precious metals and is committed to maintaining the highest standards of compliance and ethical conduct. Although Goldealers Ltd is a cash-free business and not required to register with HM Revenue & Customs (HMRC) for AML supervision, this policy reflects our dedication to proactively mitigate financial crime risks.

This policy applies to all employees, officers, and agents of Goldealers Ltd. It covers all aspects of our business operations and aims to ensure full compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the "Regulations")

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.

Proliferation Financing: The financing of the proliferation of weapons of mass destruction.

Beneficial Owner: For a body corporate or partnership, an individual who ultimately owns or controls more than 25% of the shares or voting rights, or exercises ultimate control over the management of the body. For a trust, the settlor, trustees, beneficiaries, or any other individual who exercises ultimate control over the trust For an estate of a deceased person in the course of administration, the beneficial owner is the executor or administrator of the estate

Customer Due Diligence (CDD): Verifying the identity, beneficial owners and risk levels of customers.

Simplified Due Diligence (SDD): Reduced CDD measures, applicable only in low-risk situations as specified in the regulations.

Enhanced Due Diligence (EDD): Additional CDD measures for high-risk customers or transactions.

Suspicious Activity Report (SAR): Reporting suspicious activity to the National Crime Agency (NCA).

We will assess the risk of money laundering and terrorist financing within our business. This includes looking at: Our customers; Where we operate; The products we purchase and sell (precious metals); How customers pay for goods; This risk assessment will be reviewed at least annually.

Suppliers or customers may trade up to £5,000 of precious metals in a single transaction, and up to a total value of £10,000 in a 12-month rolling window with a single form of photo ID. The ID must be an original, or certified copy of one of: Passport Drivers Licence National Identity Card

For transactions exceeding the above thresholds, we will also require a proof of address. We will accept one of the following: Drivers Licence - if not already provided as proof of identity; Phone bill; Other utility bill; Deeds; Tenancy agreement; lease agreement; Council tax bill

The abovementioned transaction limits are more stringent than our legal AML obligations, and have been derived from our obligations under VAT Notice 701/21.

Enhanced due diligence will be applied in situations where there is a higher risk of money laundering, terrorist financing, or proliferation financing. These include: Customers who are Politically Exposed Persons (PEPs), their family members, and known close associates. Complex or unusually large transactions. Customers who are beneficiaries of a life insurance policy. We do not transact outside of the EU - so have excluded 3rd countries as a trigger to conduct EDD.

Additional steps for EDD include but are not limited to: Senior management approval before engaging with a PEP; Examining the background and purpose of the transaction; Increasing the degree of monitoring. Requesting source of funds, and documents to prove beneficial ownership.

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

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.

Goldealers Ltd will maintain comprehensive records for at least six years, including: Customer identification and verification information. Transaction history. Risk assessments and policies. SARs and related documents. Training records.

These records will be readily accessible for regulatory inspections.

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

Goldealers Ltd will maintain effective internal controls to ensure adherence to this policy. This includes regular monitoring and testing of compliance.

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.