Compliance policy
AML Policy
AML content is organized for due diligence, monitoring, sanctions, reporting, responsibility, recordkeeping, and training review.
Policy Document
AML Policy
Review the GHM AML policy structure for purpose, scope, due diligence, monitoring, reporting, sanctions, responsibilities, records, training, and revisions.
- Effective Date
- Managed in ACF
Purpose
The AML policy describes how the company structures anti-money-laundering controls for precious-metals inquiries and transactions.
Scope
The policy applies to buyer onboarding, counterparty review, payment-path review, source-of-funds checks, transaction monitoring, and recordkeeping activities.
Customer Due Diligence
Customer due diligence may include identity, authority, beneficial ownership, company, destination, transaction purpose, and source-of-funds review.
Monitoring
Transactions may be monitored for unusual behavior, document inconsistencies, sanctions exposure, route risk, payment risk, or counterparties that refuse verification.
Reporting
Internal escalation and external reporting requirements should follow applicable law and administrator-approved compliance procedures.
Sanctions
Sanctions screening and destination review should be completed before allocation, payment, shipment, or document release where required.
Responsibilities
Personnel involved in sales, compliance, logistics, documentation, and finance should follow approved review workflows.
Record Keeping and Training
AML records and training materials should be retained according to approved internal schedules and legal obligations.
Contact Information
Policy Contact
Policy contact information is managed in ACF.
Revision History
Revision history is managed in ACF and displays after approved entries are added.
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