KYC & Customer Due Diligence Policy

We must know who we are dealing with, who ultimately owns and controls them, and whether their business rationale is credible, before any introduction, pricing release or transaction step.

Onboarding is a condition of engagement, not an administrative formality. Incomplete onboarding means no engagement.

• At onboarding, before an NCNDA-protected introduction or the release of LBMA spot-based pricing.
• Before execution of a sale and purchase agreement.
• When ownership, control, banking arrangements, jurisdiction or transaction profile materially changes.
• Periodically during an ongoing relationship, on a risk-based refresh cycle.
• Whenever a red flag, sanctions hit or adverse media finding arises.

• Certificate of incorporation or registration and current company extract.
• Registered address, trading address and confirmation of operating status.
• Company structure chart identifying the ownership chain to ultimate beneficial owners.
• Board resolution or authority evidencing who may bind the entity.
• Business licences relevant to precious metals dealing, where applicable in the entity's jurisdiction.

• Government-issued photographic identification for directors, authorised signatories and ultimate beneficial owners.
• Proof of residential address dated within the last three months.
• Confirmation of role and authority within the entity.
• PEP declaration covering the individual and close associates and family members.

We identify and verify each natural person who ultimately owns or controls 25% or more of the counterparty, and apply a lower threshold where risk warrants it.

Where ownership is held through trusts, nominees, bearer arrangements or layered holdings, we require documentation that explains the structure. Structures whose purpose appears to be concealment are grounds for refusal.

• Verified corporate identity and beneficial ownership as above.
• Corporate email domain and verifiable business contact details.
• Letter of Intent (LOI) or Irrevocable Corporate Purchase Order (ICPO) on company letterhead with signatory details.
• Proof of funds, bank comfort letter or equivalent evidence of settlement capacity, provided bank to bank where required.
• Confirmed destination market, delivery terms and receiving refinery or vault where relevant.
• Import and licensing capability in the destination jurisdiction.
• Signed NCNDA and, where applicable, NDA before introductions are made.

• Verified corporate identity, beneficial ownership and operating history.
• Mining, dealing or export licences valid in the country of origin.
• Evidence of lawful title to the material and its chain of custody.
• Export permit capability, certificate of origin and, where applicable, regional certification such as Great Lakes documentation.
• Assay and refinery documentation, and willingness to accept independent inspection and assay.
• Responsible sourcing declarations consistent with our Responsible Sourcing Policy.

Intermediaries are subject to the same identification requirements as principals, and must disclose the party they represent, their mandate or authority, and any fee or commission expectation.

Unverifiable broker chains, undisclosed principals and mandates that cannot be evidenced are grounds for refusal.

Documents must be current, legible and complete, in English or accompanied by a certified translation. Certified copies or verified originals are required where risk warrants it, and we may verify details independently against company registries and other reliable sources.

We cross-check the information provided against sanctions, PEP and adverse media screening, and against the commercial profile of the proposed transaction.

Enhanced measures are applied to PEPs, opaque structures, high-risk jurisdictions, unusually large or urgent transactions and any relationship where initial checks raise questions. These include additional documentation, independent verification, source of wealth enquiry, senior approval and closer ongoing monitoring.

We may decline or terminate an engagement where documentation is incomplete, inconsistent or unverifiable, where beneficial ownership cannot be established, where a sanctions or adverse media concern arises, or where the commercial rationale is not credible.

We are not required to give reasons, and a refusal is not a statement about the counterparty's conduct.

KYC material is collected for compliance purposes only, is never used for marketing, and is stored in private, access-controlled systems. Handling, retention and your rights are set out in our Privacy Policy and Data Protection Policy. Compliance records are generally retained for at least seven years.