Compliance & regulatory framework
Compliance is not
our constraint.
This page is written for compliance officers and partner bankers: what they look for, in the order they look for it.
What is weighed can be proven.
01
Entering a relationship
Every counterparty — seller, counter, carrier, refiner — is identified and cleared before the first transaction. The file covers identification, proof of activity, beneficial ownership and origin declaration. Processing time: 5 business days.
02
Screening
Systematic checks against sanctions and politically exposed persons lists, at onboarding and recurrently. The query log is time-stamped and retained as audit evidence.
03
Chain of custody
Every lot carries five mandatory items: weighing sheet, proof of producer settlement, photograph, origin declaration, seal reference — plus the assay certificate. A complete file can be reconstituted at any moment.
04
Settlement governance
Strict separation of duties, dual authorisation above USD 50,000, ring-fencing of investor funds in a dedicated account.
05
Applicable framework
DMCC free zone with annual external audit obligation. Alignment with the OECD Due Diligence Guidance for responsible mineral supply chains.
What we refuse
- A lot whose origin cannot be established or verified
- A counterparty on a sanctions list, or connected to such a person
- An incomplete documentary file, whatever the commercial urgency
- A cash settlement outside the counter purchasing circuit
Documents
The compliance charter and company profile are provided on request, once the requesting entity has been identified.