Anti-Money Laundering & Counter-Terrorist Financing Policy

Purpose

The purpose of this Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy is to ensure that Simodi Bullion FZCO ("Simodi Bullion") is not used, intentionally or unintentionally, to facilitate money laundering, terrorist financing, or proliferation financing. This Policy sets forth the standards, controls, and procedures to be followed by all employees, directors, agents, and contractors engaged in Simodi Bullion's trading activities.

Legal and Regulatory Framework

Simodi Bullion operates under the following UAE laws, regulations, and guidelines:

Simodi Bullion is committed to ongoing monitoring of regulatory developments to maintain compliance.

Scope

The Policy applies to:

• All employees, directors, contractors, and agents of Simodi Bullion
• All customers, suppliers, intermediaries, and business partners
• All gold and jewelry-related activities, including purchase, sale, import/export, refining, storage, and delivery

Core AML/CTF Principles

Simodi Bullion adopts a risk-based approach to AML/CTF, including:

Risk Assessment

Simodi Bullion conducts a formal, documented risk assessment annually to identify and mitigate AML/CTF risks. Key risk factors include:

The results of the risk assessment guide the application of Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and ongoing monitoring procedures.

Customer Due Diligence (CDD)

Before establishing any business relationship or executing transactions, Simodi Bullion:

• Identifies the customer and verifies their identity using reliable, independent documentation
• Identifies the beneficial owner(s) for corporate clients
• Determines the purpose and intended nature of the business relationship
• Conducts sanctions and PEP screening in accordance with applicable regulations
• Documents all information in a secure and retrievable manner

Enhanced Due Diligence (EDD)

EDD measures are applied to high-risk customers, jurisdictions, or transactions, including:

• Transactions involving high-risk or sanctioned jurisdictions
• Politically Exposed Persons (PEPs) and their associates
• Large, unusual, or complex cash transactions
• Transactions that deviate from expected customer behavior

Ongoing Monitoring

Simodi Bullion implements a system of continuous monitoring to:

• Track transaction volumes, patterns, and frequency
• Identify deviations from expected customer behavior
• Detect suspicious activities, such as rapid buying/selling, third-party payments, or unusual shipping instructions

All monitoring is documented and escalated to the Compliance Officer / MLRO as required.

Suspicious Transaction Reporting (STR)

Employees immediately report any suspicious activity to the Compliance Officer / MLRO.

• STRs are submitted confidentially via the goAML system to the UAE FIU
• No employee shall disclose the fact that a report has been filed
• Records of reported transactions are securely maintained in accordance with regulatory requirements

Sanctions Compliance

Simodi Bullion screens all customers, counterparties, and transactions against:

• Targeted Financial Sanctions lists (UAE Terrorist List, UN Consolidated Sanctions List)
• EOCN Sanctions
• Other relevant international sanctions lists (e.g., OFAC)

Business relationships or transactions matching a sanctions listing are immediately suspended until cleared.

Record Keeping

All AML/CTF-related records are maintained for a minimum of five (5) years, including:

• Customer identification documents and transaction records
• STR filings
• Risk assessments and reports
• Employee training records

Records are securely stored and readily retrievable for inspection by regulatory authorities.

Training and Awareness

Simodi Bullion ensures that all employees receive annual AML/CTF training, covering:

• Identification of red flags specific to gold and precious metals trading
• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures
• Sanctions compliance and restricted entities
• Suspicious Transaction Reporting (STR) procedures

Training effectiveness is regularly assessed, and records are maintained.

Independent Audit

Simodi Bullion commissions an annual independent audit to evaluate:

• Compliance with internal AML/CTF policies and procedures
• Effectiveness of controls and monitoring
• Adequacy of risk assessment and mitigation measures

Findings are reported to senior management, and corrective actions are implemented promptly.

Compliance Officer / Money Laundering Reporting Officer (MLRO)