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legal · aml

clean gold, checked.

Dealing in gold carries duties under UK money-laundering law. This is how we meet them — the checks we run, the records we keep, and why.

draft — not legal advice

DRAFT — not legal advice; must be reviewed and approved by a qualified solicitor before publication. Bracketed fields are placeholders for details to be confirmed before going live.

Our commitment

Gold is a portable store of value, which makes the trade a target for money laundering. We take that seriously. We are committed to trading only in gold whose ownership and origin we are satisfied with, to knowing who our customers are, and to playing our part in keeping criminal proceeds out of the market. These checks are not optional extras — they are conditions of doing business with us, and they protect honest customers as much as they deter dishonest ones.

The legal framework

We operate under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the "Money Laundering Regulations 2017"), the Proceeds of Crime Act 2002, and related UK law. As a dealer in high-value goods, we are registered for anti-money-laundering supervision with HM Revenue & Customs under registration number [HMRC MLR registration no.].

Identity checks (KYC)

Before we complete a transaction, we carry out customer due diligence — "know your customer" checks — proportionate to the transaction and the risk it presents. Depending on the circumstances, this may involve:

  • confirming your full name, date of birth and address;
  • verifying that information against reliable sources, such as identity documents or an electronic identity check;
  • establishing who we are ultimately dealing with where someone acts on behalf of another person or a company;
  • applying enhanced checks where the risk is higher.

We may need to repeat or update these checks over time. How we handle the data collected is set out in our privacy notice.

Source of goods & funds

We may ask how you came to own the gold you are selling, and — where relevant — about the source of funds in a purchase. This is a normal part of due diligence, not an accusation. Straightforward answers and, where needed, supporting documents let us complete the transaction promptly. We will only ask for what is proportionate to the transaction in front of us.

Record-keeping

We keep records of the due diligence we carry out and of the transactions we complete, including the evidence relied on to verify identity. The law requires us to retain these records for at least five years after our business relationship with you ends, after which we securely delete or anonymise them unless the law requires us to keep them longer.

Monitoring & reporting

We monitor transactions for activity that is unusual or inconsistent with what we know about a customer. Where we have knowledge or suspicion of money laundering, we are legally required to make a report to the relevant authority. In some circumstances the law prohibits us from telling you ("tipping off") that we have made, or may make, such a report, and may require us to pause a transaction. We comply with these obligations even where doing so means we cannot explain a delay.

When we cannot proceed

If we are unable to complete the required checks, if we are not satisfied as to identity or source, or if the law prevents us, we will decline or pause the transaction. We may also be unable to return funds or goods until our obligations are resolved. We will tell you as much as the law allows.

Responsibility & training

A nominated officer is responsible for our anti-money-laundering compliance and for handling internal reports — currently [nominated officer / MLRO]. Our staff receive training so they can recognise and act on the risks. We keep our risk assessment and procedures under review and update them as the law and our business change.