Anti-Money Laundering (AML) Policy for Stratos Bullion

Effective Date: 16th August 2023

1. Introduction

Stratos Bullion is committed to the prevention of money laundering and terrorist financing. As a UK-based business dealing in precious metals, including gold and silver coins, we adhere to all UK regulatory requirements under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. This Anti-Money Laundering (AML) Policy outlines our responsibilities and the procedures we have in place to mitigate the risk of money laundering activities and to comply with UK legislation.

2. Purpose

This policy is designed to:

  • Prevent our services from being used for the purposes of money laundering or terrorist financing.
  • Ensure we comply with all relevant UK laws and regulations related to AML.
  • Set out the responsibilities of Stratos Bullion and its staff to comply with AML regulations.

3. Scope

This policy applies to all employees, contractors, customers, and any individual or entity conducting transactions with Stratos Bullion, particularly in relation to the sale and purchase of gold and silver coins.

4. Regulatory Framework

Stratos Bullion complies with the following UK-specific regulations:

  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
  • Proceeds of Crime Act 2002
  • Terrorism Act 2000
  • HMRC guidance for businesses dealing in high-value goods, including precious metals.

5. Customer Due Diligence (CDD)

We apply customer due diligence (CDD) measures to identify our customers and verify their identity, especially for transactions exceeding £10,000 or where suspicious activity is detected.

a. Identification

For transactions over £10,000, or when a customer makes multiple smaller transactions that cumulatively exceed this threshold, we will:

  • Request proof of identity, such as a valid passport or driving licence.
  • Obtain proof of address, such as a utility bill, dated within the last 3 months.

b. Enhanced Due Diligence

In cases where there is a higher risk of money laundering, including dealing with politically exposed persons (PEPs) or international clients, we will carry out enhanced due diligence:

  • Additional checks on the source of funds.
  • Close scrutiny of the purpose of the transaction.

6. Transaction Monitoring

We monitor all transactions for any unusual or suspicious activity. This includes:

  • Large or complex transactions that do not fit the typical customer profile.
  • Structured transactions designed to avoid the £10,000 threshold.
  • Transactions with customers based in high-risk countries.

7. Reporting Suspicious Activity

If any suspicious activity is detected, we are required by law to file a Suspicious Activity Report (SAR) with the UK’s National Crime Agency (NCA). Our internal procedures include:

  • Prompt reporting of suspicious activities by staff to the designated Money Laundering Reporting Officer (MLRO).
  • Filing an SAR within the appropriate timeframe.

8. Record Keeping

We maintain detailed records of all transactions and customer due diligence for at least 5 years. These records include:

  • Copies of identification documents.
  • Details of transactions exceeding £10,000.
  • Any reports of suspicious activity filed.

9. Employee Training

All staff at Stratos Bullion receive regular AML training to ensure they:

  • Understand the importance of AML regulations.
  • Recognise suspicious behaviour or transactions.
  • Know how to report suspicious activities internally.

10. Designated Officer

The Money Laundering Reporting Officer (MLRO) at Stratos Bullion is responsible for overseeing compliance with this AML policy. The MLRO is also responsible for filing SARs with the NCA and keeping detailed records of all reports and actions taken.

11. Consequences of Non-Compliance

Failure to comply with this AML policy, whether by employees or customers, may result in legal action or sanctions. This includes reporting individuals to law enforcement authorities, the imposition of penalties, or termination of business relationships.

12. Review and Updates

This policy will be reviewed annually or whenever there are significant changes to relevant laws and regulations to ensure it remains compliant with UK law.