Anti-money-laundering

Why this exists

Precious metals are attractive to people laundering the proceeds of crime: they are compact, liquid, and hold value across borders. A custodian that does not ask questions is useful to those people, which is precisely why we ask them. If the checks below feel intrusive, that is the point of them.

Applicable law

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended; the Proceeds of Crime Act 2002; the Terrorism Act 2000

Supervisor

to be confirmed on registration

Registration number

to be supplied

Nominated officer (MLRO)

to be supplied

Registration and supervision depend on the activities actually carried on. Those fields stay blank until the registration certificate exists; ask us for it rather than taking a claim.

Before an account opens

We complete customer due diligence on every client. Nothing is deposited before it is finished.

Individuals

1. Full name, date of birth, nationality and residential address.
2. Government-issued photographic identity document, verified against the person.
3. Independent evidence of address.
4. Screening against UK sanctions lists and politically exposed person lists.

Companies, partnerships and trusts

1. Registered name, number, registered office and trading address.
2. Constitutional documents, and the register of members or equivalent.
3. Identification of every beneficial owner holding more than 25%, and of anyone otherwise exercising control.
4. Identification of the individuals authorised to instruct us.
5. For trusts, the settlor, trustees, named beneficiaries and any class of beneficiary.

Source of funds and source of wealth

These are different questions and we ask both. Source of funds is where the money or the metal for this particular transaction came from. Source of wealth is how the overall wealth was accumulated. We ask for documentary evidence, not assertions, and the level of evidence rises with the value and with the risk rating.

Risk-based approach

Each relationship is risk-rated at onboarding and reviewed periodically. Enhanced due diligence applies where any of the following is present, and is not negotiable:

• A politically exposed person, a family member or a known close associate.
• A high-risk third country listed in Schedule 3ZA of the Regulations.
• A relationship or transaction conducted without the client being physically present, where verification cannot be satisfactorily completed remotely.
• Unusual complexity, or a structure with no apparent economic or lawful purpose.
• Metal whose chain of custody cannot be established. See sanctions and sourcing.

Ongoing monitoring

We monitor the relationship for consistency with what we were told at onboarding, keep identity records current, and re-screen against sanctions lists as they are updated. A pattern that stops making sense triggers a review, and we may ask for further evidence at any time.

Cash

We do not accept cash for storage fees, carriage charges or any other payment. Payment is by bank transfer from an account in the name of the client. We do not accept third-party payments, because a payment from someone other than the client defeats the point of having identified the client.

Reporting

Where we know or suspect, or have reasonable grounds to suspect, that property represents the proceeds of crime or relates to terrorist financing, our nominated officer makes a suspicious activity report to the National Crime Agency. Where a report is made we may be prohibited by law from telling you, and doing so could be the criminal offence of tipping off. We may also have to decline or delay an instruction without being able to explain why.

Records

Customer due diligence records and transaction records are kept for five years after the business relationship ends or the occasional transaction completes, then deleted, unless a longer period is required by law or an ongoing investigation. This retention is a legal obligation and overrides a request for erasure, as explained in the privacy notice.

Training and responsibility

Staff who deal with clients or movements receive anti-money-laundering training on appointment and periodically thereafter, covering recognition of suspicion and the internal reporting route. Responsibility for the policy sits with the board.

What this means for you

Opening an account takes longer than it would at a firm that does not do this properly. We would rather be the slower firm. If we decline a relationship we are not obliged to give reasons, and in some circumstances we are prohibited from doing so.

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Questions about this document go to info@goldstarbullionsecurity.com, or write to Gold Star Bullion Security, 144 Houndsditch, London EC3A 7BX, United Kingdom.