AML & Counter-Terrorism Financing Policy

Gold Capital International has zero tolerance for money laundering, terrorism financing, proliferation financing and the handling of proceeds of crime. We will decline any transaction that we cannot satisfy ourselves is legitimate.

This policy applies to all personnel, contractors and introducers acting for GCI, and to every counterparty, transaction and jurisdiction we engage with.

We design our procedures with reference to the Financial Action Task Force (FATF) Recommendations, Australia's Anti-Money Laundering and Counter-Terrorism Financing Act 2006, and the AML expectations that refiners, banks and destination-market regulators apply to precious metals.

GCI is a private commercial business. Publishing this policy does not mean we are licensed, registered, supervised or approved by AUSTRAC or any other regulator. Whether, and in which jurisdictions, GCI or a counterparty is a reporting entity is a question for qualified legal advice, and our obligations are reassessed as our activities and jurisdictions change.

We assess each relationship and transaction for money laundering and terrorism financing risk and apply due diligence proportionate to that risk, escalating to enhanced due diligence where risk is elevated.

• Country risk: origin, transit and destination jurisdictions, including conflict-affected and high-risk areas, sanctioned or high-corruption jurisdictions and FATF-listed countries.
• Customer risk: entity structure, opacity of ownership, use of intermediaries, PEP involvement and adverse media.
• Product risk: doré versus refined bullion, physical form, and the ease with which value can be moved.
• Channel risk: non-face-to-face onboarding, unverifiable introductions and chains of brokers.
• Transaction risk: value, urgency, payment structure and commercial logic.

No introduction, pricing release or transaction proceeds until customer due diligence is complete and satisfactory. Identification and verification requirements are detailed in our KYC Policy.

Enhanced due diligence — including additional documentation, independent verification, senior sign-off and closer ongoing monitoring — is applied to PEPs and their associates, complex or opaque ownership structures, high-risk jurisdictions and unusually large or urgent transactions.

Buyers must be able to evidence the origin of the funds used for settlement and, where risk warrants it, the wealth underlying them. Acceptable evidence includes audited financial statements, bank statements or references, a bank comfort letter, or documentation of the underlying commercial activity.

We do not accept cash settlement, third-party payments from unrelated entities, or funding routed through jurisdictions or structures that cannot be explained commercially.

Sellers must evidence lawful title and origin of material, including mining or trading licences, export permits, certificates of origin, assay and refinery documentation and, where applicable, Great Lakes regional certification.

Material that cannot be traced to a lawful, documented source is rejected. Responsible sourcing due diligence is applied in parallel under our Responsible Sourcing Policy, consistent with OECD due diligence guidance for minerals from conflict-affected and high-risk areas.

All counterparties, directors, beneficial owners, vessels, carriers and banks involved are screened against United Nations, Australian, OFAC, UK and EU sanctions lists, and for PEP status and adverse media, before engagement and periodically thereafter. See our Sanctions Compliance Policy.

• Reluctance or inability to provide identification, ownership or licensing documents.
• Ownership structures with no commercial rationale, nominee arrangements or shell companies in secrecy jurisdictions.
• Pressure to bypass compliance steps, or unusual urgency inconsistent with the transaction size.
• Requests to split payments, to pay third parties, to use personal accounts or to accept cash.
• Pricing significantly away from market, or terms that make no commercial sense.
• Documentation that appears altered, inconsistent, templated or unverifiable.
• Counterparties introduced through unverifiable broker chains, or refusal to sign an NCNDA or NDA.
• Origin, transit or destination routing that has no logistical logic.

Personnel must escalate any suspicion to the Director immediately and must not progress the transaction pending review. The Director determines whether to decline, pause or report.

Where a reporting obligation applies in a relevant jurisdiction, a suspicious matter report is filed with the competent authority with the assistance of qualified legal counsel. Where a report is made, personnel must not disclose that fact to the counterparty or any third party.

Declining a transaction is always an available and acceptable outcome, and no commercial target justifies proceeding with an unresolved suspicion.

Active relationships are monitored for changes in ownership, sanctions status, adverse media, jurisdiction and transaction behaviour. Compliance information is refreshed periodically and whenever a material change occurs.

Identification records, screening results, due diligence findings, transaction documentation and the reasons for accepting or declining a counterparty are retained for at least seven years from the end of the relationship or completion of the transaction, and are stored securely with restricted access.

Personnel receive AML and CTF awareness briefing appropriate to their role before handling counterparty information, and refresher briefings as risks and obligations change.

The Director is accountable for this policy. It is reviewed at least annually, and after any material change to our activities, jurisdictions or applicable law, with input from qualified legal counsel.