Goldealers

Goldealers Ltd operates as a high-value precious metals dealer and maintains a strict cash-free business model. In accordance 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 anti-money laundering (AML) purposes.

However, despite our exemption from HMRC registration, Goldealers Ltd is committed to upholding the highest standards of integrity and transparency. We have proactively implemented an AML policy designed to mitigate the risk of our business being used for money laundering or terrorist financing activities. This policy includes the following measures:

As a cash free business, Goldealers Ltd do not need to register for money laundering supervision with HMRC. That said, we do

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. It encompasses all business activities conducted by Goldealers Ltd within the UK.

3. Definitions

Money Laundering: The process of concealing the origins of money obtained illegally by passing it through a complex sequence of banking transfers or commercial transactions. Terrorist Financing: The provision of funds or financial support to individuals or groups engaged in terrorist activities.
Supplier Due Diligence (CDD): The process of verifying the identity of suppliers and assessing the risks they may pose.
Customer Due Diligence (CDD): The process of verifying the identity of customers and assessing the risks they may pose.
Suspicious Activity Report (SAR): A report filed with the National Crime Agency (NCA) when suspicious activity is detected.

4. Supplier Due Diligence

Transaction Limits

Suppliers can sell up to £5,000 of precious metals using a single form of ID.Companies: Obtain and verify the company name, registration number, registered address, and identities of directors and beneficial owners.

Individuals: Obtain and verify full name, photograph on an official document (e.g., passport, driving license), date of birth, and residential address.
Companies: Obtain and verify the company name, registration number, registered address, and identities of directors and beneficial owners.

6.2 Risk Assessment

Risk-Based Approach: Assess the level of risk associated with each customer. Factors to consider include the customer‘s background, geographical location, and the nature of the transaction.
Enhanced Due Diligence (EDD): Apply EDD measures for higher-risk customers, including those from high-risk jurisdictions or involved in large, complex transactions.

7. Ongoing Monitoring

Continuously monitor customer transactions for unusual or suspicious activity. Maintain updated customer information and review CDD records periodically.

8. Suspicious Activity Reporting

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

9. Record Keeping

Maintain all records of CDD, transactions, and SARs for at least five years. Ensure records are readily available for inspection by regulatory authorities.

10. Training and Awareness

Provide regular AML training to all employees to ensure they understand their responsibilities and the latest regulatory requirements. Training should include identifying suspicious activities, CDD procedures, and reporting obligations.

11. Internal Controls and Audits

Implement robust internal controls to ensure compliance with this policy. Conduct regular audits to assess the effectiveness of the AML program and identify areas for improvement.

12. Review and Update of Policy

This policy will be reviewed annually or as required by changes in regulations or business practices. The AML Compliance Officer is responsible for ensuring the policy remains current and effective.