Anti-Money Laundering & KYC Policy

1. Statutory Mandate & Legal Framework

Aurum East Africa Precious Metals Limited conducts all operations in strict conformity with the Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) of Kenya, the Mining Act (No. 12 of 2016), and applicable regional financial intelligence guidelines, including CENAREF in the Democratic Republic of Congo and the Financial Intelligence Unit (FIU) of South Sudan.

2. Zero Tolerance for Cash Dealings

To eliminate money-laundering risks, Aurum East Africa enforces a strict Zero Over-The-Counter Cash Policy. All physical bullion purchases, doré settlements, and transaction fees must be executed via verified corporate or personal commercial banking channels (RTGS, Fedwire, SWIFT) or through authorized commercial escrow facilities.

3. Counterparty Due Diligence Requirements

Before issuing a bullion sales agreement, our compliance department requires:

• Individual Buyers: Valid government-issued passport or national ID card, recent proof of physical residential address (< 90 days), and proof of legitimate source of funds.
• Corporate Entities: Certified Certificate of Incorporation, Memorandum and Articles of Association, official CR12 listing beneficial ownership (> 10% threshold), and ID of authorized directors.
• Gold Provenance Records: Mining titles, cooperative extraction permits, and official transport waybills documenting the origin of bullion offered for sale.

4. Sanctions Screening

All counterparties and beneficial owners are screened against international sanctions databases, including the United Nations Security Council Consolidated List, the United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals List, and European Union sanctions registries. Any match results in immediate transaction termination and mandatory regulatory reporting.