Anti-money-laundering policy.

Bullion Street Gold Trading L.L.C, its shareholders, directors and senior management are firmly committed to the efforts of the UAE government and the international community to fight money laundering and the financing of terrorism. BSGTR has implemented an AML programme designed to reasonably mitigate the risks of money laundering, terrorist financing and the financing of illegal organisations, and to ensure compliance across the full scope of its current activities.

The company is committed to the responsible sourcing of precious metals guidance issued by the OECD, the DMCC and the LBMA. Compliance with the AML programme and its implementing regulations is a condition of employment for every director, officer and employee, and every member of staff is required to play an active role in preventing the use of BSGTR's operations for illicit activity.

• We abide by the rules issued by the relevant authorities and assist regulators in combating money laundering and terrorist financing.
• Our products and services are not used to launder the proceeds of crime or to assist terrorist financing.
• Our staff understand their obligations and the need for vigilance.
• We provide ongoing AML / CFT training reflecting the latest regulations from the Central Bank of the UAE.

BSGTR operates a risk-based Anti-Money Laundering compliance programme designed to comply with UAE law and with international good practice, including the FATF 40+9 recommendations, US sanctions programmes, the Counter Terrorism Act 2008 and the Anti-terrorism, Crime and Security Act 2001. The programme consists of:

• Written policies, procedures and a system of internal controls that support ongoing compliance with applicable AML laws and regulations.
• Know Your Customer standards, including a Customer Identification Programme and Customer Due Diligence procedures to identify and verify all customers and, where applicable, beneficial owners, source of funds and the nature and purpose of the business relationship.
• Additional due diligence on higher-risk customers and on politically exposed persons.
• Risk-based measures and systems for the ongoing monitoring of transactions.
• Identification and reporting of suspicious transactions or activities to the appropriate regulatory authorities.
• AML training for relevant personnel.
• Independent audit and compliance testing to review and assess adherence to the programme and to applicable law.
• A prohibition on conducting business with shell banks.
• Record keeping and reporting, with records retained for at least five years after the end of a customer relationship.
• AML risk assessments at programme, customer, product and service level, both qualitative and quantitative.
• An independent compliance function reporting directly to the shareholders.

BSGTR is committed to the following UAE AML / CFT laws and regulations:

• Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations.
• Cabinet Decision No. (10) of 2019 on the implementing regulation of Federal Decree-Law No. (20) of 2018.
• Federal Decree-Law No. (26) of 2021 amending certain provisions of Federal Decree-Law No. (20) of 2018.
• Cabinet Decision No. (74) of 2020 on the terrorist list system and the implementation of Security Council resolutions on preventing and suppressing terrorism and its financing.
• Cabinet Decision No. (24) of 2022 amending Cabinet Decision No. (10) of 2019.
• Other related decisions, AML / CFT guidelines and anti-terrorism legislation.

We also follow international law, best practice and industry standards, including the FATF 40+9 Recommendations, MENAFATF, the Asia Pacific Group on Money Laundering, UNODC guidance, the Counter Terrorism Act 2008 and the Anti-terrorism, Crime and Security Act 2001.

BSGTR's compliance function operates under a Code of Conduct that sets out effective working methods and ethics, built on integrity, objectivity, confidentiality and competency.

Its mission is to ensure that operational compliance standards and procedures are established and followed, to assist with the implementation and enhancement of internal controls, and to support an ethical working environment that contributes to the company's mission.

An approved Compliance Charter defines the department's purpose within the company; its authority to access information, initiate investigations, reach the shareholders without restriction and engage external expertise; and its responsibilities and reporting lines.

No sale or purchase transaction proceeds without the formal approval of the compliance department. Compliance begins the process by conducting KYC on every customer or supplier before the operations team may initiate a transaction. KYC establishes the identity and beneficial ownership of accounts, the source of funds and the nature of the customer's business. It is mandatory, and it is not a one-time exercise: it is ongoing and continuous.

Customers fall into two categories: natural persons (resident and non-resident individuals) and legal entities (corporate customers). Cash purchases of small investment bars by retail customers are honoured without the need to open an account.

Customer Due Diligence lets us assess the extent to which a customer is exposed to a range of risks. Through CDD the compliance department:

• Identifies and verifies counterparties before establishing a business relationship. Only the identified person, or their fully identified and authorised agent, may receive payment or delivery, unless a legitimate, documented business reason exists and any third party has been identified and verified.
• Identifies beneficial owners and takes reasonable measures to verify their identity, including understanding the ownership and control structure of legal persons and arrangements.
• Obtains information to understand the customer's circumstances and business, including the expected nature and level of transactions.
• Understands the source of funds for transactions and the source of wealth for continuing relationships.
• Updates KYC information for every retail and corporate client on the renewal schedule.

Enhanced Due Diligence adds measures beyond standard customer due diligence to learn more about a customer and their transactions, confirming that the transactions and funds are legitimate and free from any criminal link.

EDD is not required in every case. It applies where the combination of customer and product or service presents greater risk, and wherever there is doubt or suspicion about a customer's activities. This higher level of diligence mitigates the increased risk.

BSGTR performs real-time name screening on every customer, beneficiary, beneficial owner, partner, shareholder, representative and every other party to a transaction. Every onboarding and every transaction is screened against blacklisted and sanctioned entities. When an alert is investigated, the Compliance Officer / MLRO considers full name, nationality, date of birth and place of birth to identify possible matches. Customer details are screened against:

• UNSC — United Nations Security Council Consolidated List
• UAE Local Terrorist List
• OFAC — Specially Designated Nationals (SDN) List
• OFAC — Consolidated Sanctions List
• EU Consolidated List
• Dow Jones
• BSGTR's internal watch list

BSGTR uses AML Trace to screen customers against recognised sanctions and politically exposed persons lists. We conduct EDD on all PEPs, foreign PEPs, heads of international organisations, PEP associates and diplomatic passport holders — whether natural-person customers or the beneficial owners of legal persons. Every relationship is reviewed and re-verified at least annually, or before the first transaction following a twelve-month gap.

BSGTR monitors transactions on an ongoing basis to identify potentially suspicious activity proactively, applying customisable, risk-sensitive monitoring rules and, where appropriate, third-party tools for automated detection.

We file a Suspicious Activity Report or Suspicious Transaction Report with the UAE Financial Intelligence Unit whenever there are reasonable grounds to suspect that a transaction or funds represent the proceeds of crime. Filing is not merely a legal obligation: it is a critical part of the UAE's effort to combat financial crime and protect the integrity of its financial system.

BSGTR runs a comprehensive AML / CFT training programme for all employees, including senior management, in the belief that effective training builds good corporate governance. Training is delivered to new and existing staff whenever policies and procedures are updated, and covers:

• An overview of money laundering and the financing of terrorism, including definitions, typologies and recent trends.
• The Central Bank of the UAE's AML / CFT requirements.
• Risks associated with the products and services the company offers.
• KYC and KYCC policies, Enhanced Due Diligence and the risk-based approach.
• How to identify suspicious activities and transactions.
• Record-keeping and reporting requirements, and familiarity with AML forms.
• Employees' legal obligations and responsibilities.

Record keeping ensures the company can provide basic information about its customers whenever a relevant authority requests it. BSGTR makes its books and records available immediately on request by any regulatory agency.

All records and documents relating to transfers are kept for a minimum of five years from the date of the transaction, and the confidentiality of the information in transaction records is maintained at all times.