Gold Brick Gold Trading LLC
AML Policy and Compliance

Anti-Money Laundering Policy

Our commitment to preventing financial crime and ensuring transparent, compliant gold transactions

GOLD BRICK GOLD TRADING LLC is fully committed to the highest standards of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) compliance. As a licensed precious metals trading company operating within the Dubai Multi Commodities Centre (DMCC), we adhere to UAE Federal Law, FATF Recommendations, and international best practices.

This policy outlines our framework for preventing, detecting, and reporting suspicious activities related to money laundering, terrorist financing, and other financial crimes.

Regulatory Framework

Our AML/CFT program complies with the following regulations:

UAE Federal Law No. 20 (2018)

On Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organizations

FATF 40 Recommendations

Financial Action Task Force standards for high-risk commodities and DNFBPs

DMCC AML/CFT Rules

Dubai Multi Commodities Centre protocols for precious metals trading

UAE goAML Reporting

Financial Intelligence Unit reporting obligations for suspicious transactions

Core AML/CFT Principles

Know Your Customer (KYC)

Comprehensive identity verification and ongoing due diligence for all clients and counterparties

Risk-Based Approach

Enhanced due diligence for high-risk jurisdictions, PEPs, and complex ownership structures

Ongoing Monitoring

Continuous transaction monitoring and periodic review of customer relationships and activities

KYC/KYB Requirements

Mandatory documentation for all counterparties

Individual Clients

  • •Valid passport or Emirates ID
  • •Proof of address (utility bill, bank statement)
  • •Source of funds declaration
  • •Bank account verification
  • •PEP screening and adverse media check
  • •Signed client agreement and declarations

Corporate Clients

  • •Trade license / Certificate of incorporation
  • •Memorandum and Articles of Association
  • •Full UBO (Ultimate Beneficial Owner) structure
  • •Board resolution authorizing transaction
  • •Authorized signatory identification
  • •Financial statements and business activity proof

Red Flags & Suspicious Activity

Indicators that trigger enhanced scrutiny or transaction rejection

We immediately flag and investigate transactions involving:

Unusual or structurally complex transactions
Cash transactions exceeding AED 55,000
Refusal to provide KYC documentation
Customers from high-risk jurisdictions
Politically Exposed Persons (PEPs) without proper disclosure
Mismatch between stated business activity and transaction
Rapid movement of funds with no clear economic purpose
Use of shell companies or nominees
Transactions involving sanctioned entities or individuals
Unusual shipping routes or destinations
Inconsistent documentation or forged certificates
Attempts to avoid reporting thresholds

Transaction Monitoring & Reporting

Real-Time Screening

  • Sanctions lists (OFAC, UN, EU, UK)
  • Adverse media monitoring
  • PEP databases
  • High-risk jurisdiction alerts

Threshold Monitoring

  • Cash transactions ≥ AED 55,000
  • Cumulative transaction patterns
  • Cross-border movements
  • Multiple related transactions

Suspicious Activity Reports

  • Immediate filing with UAE goAML
  • Internal escalation protocols
  • Transaction suspension when required
  • Detailed audit trail maintained

Staff Training & Compliance Culture

All employees receive mandatory AML/CFT training upon hiring and annual refresher courses covering:

  • •UAE AML/CFT legal framework
  • •Red flag identification
  • •Customer due diligence procedures
  • •Suspicious activity reporting
  • •Sanctions screening protocols
  • •Record-keeping requirements
  • •Confidentiality and tipping-off prohibitions
  • •Internal escalation procedures

Record Keeping & Data Retention

In compliance with UAE regulations, we maintain comprehensive records for a minimum of 5 years from the date of transaction completion, including:

KYC/KYB documentation
Transaction records and invoices
Due diligence reports
Screening results and alerts
Correspondence with clients
Chain-of-custody documentation
Suspicious activity reports
Internal investigation notes

All records are stored securely with restricted access and protected by encryption and backup systems.

AML Compliance Officer

For inquiries related to our AML/CFT program or to report suspicious activities:

GOLD BRICK GOLD TRADING LLC

AML Compliance Department

📧 moses@seagolds.com

📞 +971 50 156 4019

📍 Dubai, United Arab Emirates

This policy is reviewed and updated annually or as required by regulatory changes.
Last updated: December 2024

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