This policy sets out AuHandel’s approach to:

• Preventing and mitigating money laundering and terrorism financing risks.
• Conducting risk-based counterparty due diligence (KYC) and ongoing monitoring.
• Identifying and escalating suspicious activity indicators.
• Maintaining appropriate records for audit readiness and legal compliance.

This policy applies to:

• All transactions and business relationships involving AuHandel, including brokerage/execution arrangements and institutional gold trading activity.
• All counterparties (suppliers, buyers, intermediaries), and relevant service providers (e.g., logistics/custody/payment-related service providers where relevant).
• AuHandel does not engage in retail bullion sales.

AuHandel commits to:

• Apply risk-based counterparty due diligence and transaction review commensurate with risk.
• Identify and escalate higher-risk relationships and apply enhanced due diligence (EDD) as needed.
• Decline or disengage where risks cannot be mitigated to an acceptable level, where information is materially inconsistent, or where there are credible indicators of illicit finance.
• Maintain appropriate records and documentation supporting onboarding and transaction decisions.
• Train relevant personnel on AML/CTF red flags and escalation procedures.

AuHandel conducts counterparty due diligence appropriate to the relationship and transaction profile. Depending on risk, due diligence may include:

• 4.1 Verification of legal entity and authority — legal entity identification and registration information; verification of authorised signatories and authority to transact; understanding of the counterparty’s role in the supply chain.
• 4.2 Ownership and control (as applicable) — identification of beneficial ownership/control where relevant to risk and legal requirements; assessment of complex or opaque ownership structures as potential risk indicators.
• 4.3 Purpose and expected activity — understanding the nature of the relationship, expected transaction types, and settlement expectations; evaluation of whether the proposed activity is consistent with the counterparty profile.
• 4.4 Risk screening (as applicable) — geographic risk and CAHRA exposure screening; adverse information screening and integrity risk review; sanctions considerations where applicable.

AuHandel applies EDD where higher-risk indicators exist. Triggers may include:

• High-risk jurisdictions or CAHRA exposure.
• Unusual or opaque settlement structures.
• Third-party payments without clear legitimate rationale.
• Significant inconsistencies in documentation or origin narratives.
• Attempts to avoid standard onboarding or documentation.
• EDD measures may include additional identity/ownership documentation; clarification and corroboration of transaction rationale; expanded screening and senior management approval; tightened settlement controls and conditions (e.g., restrictions on payment pathways).

AuHandel applies controls designed to reduce AML/CTF risk, including:

• 6.1 Settlement transparency — seeks transparent settlement arrangements and may decline cash-intensive structures, unexplained third-party payments, or unusual beneficiary/routing arrangements without credible justification.
• 6.2 Documentation integrity — reviews documentation for internal consistency and plausibility; material inconsistencies or attempts to misrepresent information are escalated.
• 6.3 Ongoing monitoring (risk-based) — may conduct periodic reviews especially where risk context changes, transaction patterns change materially, or new adverse information arises.

Examples of indicators that may require escalation, enhanced checks, or refusal:

• Requests to bypass or minimise documentation.
• Pressure to execute urgently while resisting due diligence.
• Unusual payment routes, third-party payments, or frequent changes to settlement instructions.
• Inconsistent entity/ownership information or unclear authority to transact.
• Implausible origin narratives or documentation that appears altered/inaccurate.
• Transactions that lack an apparent legitimate economic rationale.
• Behaviour suggesting structuring to avoid oversight or reporting.

AuHandel uses an escalation approach for elevated AML/CTF risks:

• Front-line identification → Compliance review → Senior management decision (where required).
• Documented decisions: approve, conditionally approve (controls), suspend pending investigation, or decline/disengage.
• Where suspicious activity is identified, AuHandel will act in accordance with applicable legal obligations, which may include making reports to relevant authorities and/or refusing the transaction. (AuHandel does not publish details of reporting thresholds or internal detection methods.)

AuHandel retains records relating to:

• Counterparty due diligence (KYC/EDD).
• Transaction documentation and settlement details.
• Risk assessments, escalations, and decisions.
• Training and program reviews.
• Records are retained for periods consistent with applicable laws and operational requirements.

AuHandel provides periodic training to relevant personnel on:

• AML/CTF risks in precious metals supply chains.
• Red flags and escalation procedures.
• Documentation integrity and fraud prevention.
• Interaction between AML/CTF controls and responsible sourcing due diligence.

Concerns relating to illicit finance risks or suspected misconduct may be reported via:

• Email:complaints@auhandel.com
• AuHandel treats reports discreetly and prohibits retaliation for good-faith reporting.

This policy is reviewed at least annually and updated as needed based on:

• Legal/regulatory changes.
• Operational changes.
• Evolving risk context and learnings from implementation.