LICENSED DEALER OF PRECIOUS METALS & STONES
HONG KONG CUSTOMS & EXCISE DEPARTMENT
CAT A REG NUMBER: A-B-23-12-03254
Combating Anti-Money Laundering, Counter-Financing of Terrorism & Human Rights Violation
Compliance with the national and international provisions on the prevention of money laundering and terrorism financing and the responsible due diligence throughout the entire supply chain, from precious metals to energy products, both upstream and downstream, are of high importance for our Company. It is our policy to conduct vigorous due diligence for the selection and verification of all our commercial buy and sell partners in the gold and energy sector to confirm that they comply within international legal bounds. Our Company adheres to all national, multinational and supranational foreign trade regulations, in particular to the applicable export and import prohibitions and sanctions, official approval requirements as well as the applicable duty and tax requirements.
For precious metals such as gold, we make sure all supplies in our procurement are of conflict-free sources as per the London Bullion Market Association (LBMA) gold compliance system which includes an obligation to abstain from sourcing gold in regions where there are armed conflicts or serious violations of human rights. Should such precious minerals originate from any conflict countries, mandatory declarations from internationally recognized bodies such as the Union Nations must be obtained to verify the supplier’s mine(s) are not in any violation of criminal, conflict and/or human rights acts, for exemption to legally export and trade.
Anti-money laundering and counter-financing of terrorism international standards of anti-money laundering and counter-financing of terrorism (AML/CFT) are set by the Financial Action Task Force (FATF). Hong Kong, where our Company is based, is a member of the FATF, and as such Hong Kong implements recommendations promulgated by this inter-government body to combat money laundering, terrorist financing and proliferation financing.
In Hong Kong, the main pieces of legislation that are concerned with money laundering, terrorist financing and proliferation financing are the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), the Drug Trafficking (Recovery of Proceeds) Ordinance (DTROP), the Organized and Serious Crimes Ordinance (OSCO), the United Nations (Anti-Terrorism Measures) Ordinance (UNATMO), the United Nations Sanctions Ordinance (UNSO) and the Weapons of Mass Destruction (Control of Provision of Services) Ordinance (WMD(CPS)O).
The AMLO imposes on financial institutions, including licensed corporations and virtual asset service providers licensed by the SFC under the AMLO (SFC-licensed VAS Providers), and designated non-financial businesses and professions, requirements regarding customer due diligence and record-keeping.
The DTROP, the OSCO and the UNATMO impose statutory obligations for reporting suspicious transactions where a person knows or suspects that any property represents proceeds of (or was, or is intended to be, used in connection with) drug trafficking or an indictable offense, or that any property is terrorist property.
The UNATMO and regulations under the UNSO implement sanctions imposed by the United Nations Security Council, whereas the WMD(CPS)O controls the provision of services that are suspected to be related to proliferation of weapons of mass destruction.
The SFC’s Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations and SFC-licensed Virtual Asset Service Providers) sets out the relevant AML/CFT statutory and regulatory requirements, and the AML/CFT standards which licensed corporations and SFC-licensed VAS Providers should meet in order to comply with the statutory requirements under the AMLO. It also provides practical guidance to assist licensed corporations and SFC-licensed VAS Providers, and their senior management in designing and implementing their own policies, procedures and controls so as to meet the relevant AML/CFT statutory and regulatory requirements.
To view the legal and regulatory requirements, please click here.
For other publications and information sources regarding AML/CFT, please click here.