Resources and Regulations

The Company has implemented a risk-based Anti-Money Laundering ("AML") Compliance Program (“AML Program”) designed to comply with AML laws and regulations in the UAE., including other good practices followed internationally such as compliance with FATF 40+9 recommendations, U.S sanctions programs, Counter Terrorism Act 2008 (CTA 2008), Anti-terrorism, Crime and Security Act 2001, (ATCSA 2001), etc. The AML Program consists of, among other things:

• Written policies, procedures, and a system of internal controls designed to facilitate ongoing compliance with applicable AML laws and regulations;
• Know Your Customer (KYC) standards including a Customer Identification Program and Customer Due Diligence procedures reasonably designed to identify and verify all customers and, where applicable, beneficial owners, source of funds, and the nature and intended purpose of the business relationship, to the extent warranted by the risk of money laundering or terrorist financing or as required by regulation;
• Performance of additional due diligence on higher risk customers, and those who are assessed to be politically exposed persons;
• Risk-based measures and systems for ongoing monitoring of transactions;
• Identification and reporting of suspicious transactions or activities to appropriate regulatory authorities in accordance with applicable laws;
• AML training for appropriate personnel;
• Independent audit and compliance testing functions to review and assess the Company for compliance with the AML Program and applicable laws;
• Prohibition from conducting business with shell banks;
• Record keeping and reporting requirements, which are maintained for at least five years after the termination of a customer relationship;
• AML risk assessments at the program, customer, product and services levels (Qualitative and Quantitative aspects); and
• Independent Compliance function directly reporting to the Shareholders.

BSGT is committed to comply with the following UAE AML/CFT laws and regulations as well International regulations:

• Federal Decree Law No (20) of 2018 on AML and Combating the Financing of terrorism and Financing of Illegal Operations
• Cabinet Decision No (10) of 2019 regarding implementation of Federal Decree Law No (20)
• Federal Decree Law No (26) of 2021, to amend certain provisions of Federal Decree Law No (20) of 2028
• Cabinet Decision No (74) of 2020 regarding the terrorist list system and the implementation of Security Council resolutions related to 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 Legislations.

International laws, Best practices and industry standards, including:

• Financial Action Task Force (FATF) 40+9 Recommendations
• Middle East & North Africa Financial Action Task Force (MENAFATF)
• Asia Pacific Group on Money Laundering
• UNODC
• Counter Terrorism Act 2008 (CTA 2008)
• Anti terrorism , Crime and Security Act 2001, (ATCSA 2001)

‘Code of Conduct’ – BSGT’s Compliance Function

BSGT’s Compliance function has developed Code of Conduct for the compliance function which ensure the effective work methods and ethics within the practice. It ensures the following:

‘Mission Statement’ – BSGT’s Compliance Function

Our mission is to ensure operational compliance standards and procedures are established and followed, to assist with the implementation and enhancement of internal controls, and to support an ethical work environment to effectively contribute to the pursuit of the Company mission.

• Integrity;
• Objectivity;
• Confidentiality; and
• Competency.

‘Compliance Charter’ – BSGT’s Compliance Function

We at BSGT have approved Compliance Charter in place which helps the compliance department to understand the following:

• Their Purpose of existence in the Company;
• Their Authority in order to discharge their duties such as access on information, initiate investigations, easy and unrestricted access to shareholders and access to external expert resource;
• Their Responsibilities, so that they are aware of their work and reporting lines.

Know Your Customer / Supplier (KYC/S) And Account Opening

We have strict policy within the company to restrict any sale or purchase transaction without the formal approval of Compliance Department. Compliance department kick off the process by conducting KYC of customers or Suppliers before the operations department wants to initiate the either sale or purchase transaction. The main objective of Know Your Customer (KYC) is to determine the identity and beneficial ownership of accounts, source of funds, the nature of customer’s business and more. KYC process is mandatory and not a one-time process. It is on- going and continuous.

Customers are grouped into two (2) categories:

• Natural Persons (Individual Customer)
  • Resident
  • Non-Resident
• Legal Entities (Corporate Customers)

Customer Due Diligence (CDD)

Customer Due Diligence enables an organization to assess the extent to which its customer is exposed to a range of risk. By performing CDD, compliance department ensures to:

• Identify and verify counterparties/customers before establishing a business relationship, such as entering into contractual commitments. This identified natural or legal person or authorized and fully identified agents should then be the only person or persons to whom payment is authorized to be made, or product delivered, unless legitimate and documented business reasons exist, and any third party is appropriately identified, and its identity verified.
• Identify beneficial owners and take reasonable measures to verify the identities, such that we are reasonably satisfied that we know who the beneficial owners are. The measures which must be taken to verify the identity of the beneficial owner will vary depending on the risk. For legal persons and arrangements this should include taking reasonable measures to understand the ownership and control structure of the counterparty/customer.
• Obtain information to understand the counterparty’s/customer’s circumstances and business, including the expected nature and level of proposed transactions.
• For processing transactions, understand the customer's source of funds.
• For continuing overall business relationship, understand the customer's source of wealth; and
• During KYC renewing schedule, update KYC information for each client, retail and corporate.

Enhanced Due Diligence (EDD)

Enhanced due diligence (EDD) is to take additional measures, besides usual customer due diligence, to know more about the customer and his / her transactions to confirm that the transactions and funds are legitimate and free from any criminal link.

Enhance due diligence is not required in all circumstances; it is applied where the customer and the product/service combination are a greater risk and in cases where there is a doubt or suspicion with regard to the activities conducted by the customer. This higher level of due diligence is required to mitigate the increased risk.

Sanction & PEP Screening

BSGT is configured to execute a real – time name screening on every customer, beneficiary / beneficial owner / partner’s /shareholders, representatives, and all parties involved in the transaction activity. Every customer onboarding and Transaction is screened related to blacklisted or sanctioned entities. Therefore, when a generated alert is investigated, the Compliance Officer / MLRO considers the following variables to identify possible matches:

1. Full Name
2. Nationality
3. Date of Birth
4. Place of Birth

Sanctions screening refers to the process of screening customer details against the different lists of sanctions for PEP status and whether the customer is involved in money laundering or terrorist activities. The customer details are screened in the following list:

• UNSC: United Nations Security Council Consolidated List.
• UAE - Local Terrorist List
• OFAC: Office of Foreign Assets Control - Specially Designated Nationals List (SDN)
• OFAC: Office of Foreign Assets Control - Consolidated Sanctions List.
• EU: European Union Consolidated list.
• Dow Jones; and
• Internal Watch List.

Bullion Street Gold Trading LLC (BSGTR) makes use of ‘AML Trace’ to screen customers against recognized Sanctions Lists and Politically Exposed Persons (PEPs) lists.

Bullion Street Gold Trading LLC (BSGTR) will take all required steps to ensure that all customers with whom a business relationship is established are screened against relevant notices.

We are conducting EDD on all PEPs / FPEPs / HIOs / PEP Associates / Diplomatic Passport Holders, whether natural person customers or the UBOs of legal persons or legal arrangements. Upon establishing a relationship with the customer, we ensure that that the customer undergoes review checks and verification at least on an annual basis or prior to carrying out the first transaction following the expiration of the 12-month period.

Transaction Monitoring

BSGT regularly monitors transactions to proactively identify potentially suspicious activity based on risk sensitivity. Common approaches to transaction monitoring include the customizable transaction monitoring rules or engaging a third-party vendor to assist with the development and implementation of automated rules.

Reporting of Unusual or Suspicious Transactions

BSGT file Suspicious Activity Report (SAR)/Suspicious Transaction Report (STR) upon having reasonable grounds to SUSPECT a transaction or funds representing all or some proceeds. STR filing is not simply a legal obligation; it is a critical element of the UAE’s effort to combat financial crime and protect the integrity of its financial system. By filing STRs with the UAE FIU, BSGT alert law enforcement about suspicious behavior and allow investigators to piece together transactions occurring across multiple LFIs or DNFBPs.

Staff Training

BSGT has implemented the comprehensive AML & CFT training program to all employees including the Senior Management. The Shareholders of the company strongly believes that effective AML Training will help the company to develop a good corporate governance within the Organization.

BSGT’s AML/CFT training materials includes:

• Overview of Money Laundering / Combating Financing of Terrorism
• Definition of ML, TF and typologies as well as recent trends
• Central Bank of UAE’s AML / CFT Requirements
• Risk associated with the products and services offered by the company.
• KYC / KYCC policies, EDD and RBA
• How to identify suspicious activities and transactions
• Record-keeping and reporting requirements
• Familiarity with Anti-Money Laundering forms
• Employees legal obligation and responsibilities

Anti-Money Laundering and Combating Financing of Terrorism training is part of the compliance program and training is provided to all new staff and existing staff regarding updates in AML/CFT policies & procedures.

Record Keeping & Confidentiality

Record-Keeping ensures that the company is able to provide basic information about its customers at the request of relevant authorities. BSGT shall immediately make available any or all of its books and records upon request by any regulatory agency.

"All the records / documents of transfers should be kept for a minimum period of 5 years from the date of transaction”.

BSGT shall at all times maintain the confidentiality of information indicated in the transaction records.