Anti-money Laundering Policy

Copyright © 2025 Randburg Coin (Pty) Ltd

Copyright © 2025 Randburg Coin (Pty) Ltd

ANTI-MONEY LAUNDERING POLICY

1. Introduction

This company is committed to carrying on business in accordance with the highest ethical standards.  This includes complying with all applicable laws and regulations aimed at combating money laundering and terrorist financing.  The management is committed to complying with all laws.  Any employee who violates the rules in this Policy or who permits anyone to violate those rules may be subject to appropriate disciplinary action, up to and including dismissal, and may be subject to personal civil or criminal fines.

2. Policy Statement

This company will only conduct business with customers who are involved in legitimate business activity and whose funds are derived from legitimate sources. This is intended to help employees, contractors to understand where breaches of laws might arise and to support them in making the right decisions.

3. Parties

This applies to our company business and to all directors, officers, employees, contractors, and other third parties.

4. Possible risks

Violations may lead to severe civil and criminal penalties against companies and individuals, including significant monetary fines, imprisonment, extradition, blacklisting, revocation of licences, and disqualification of directors. Violations can lead to damaging practical consequences, including harm to reputation and commercial relationships, restrictions in the way we can do business, and extensive time and cost in conducting internal investigations and defending against government investigations and enforcement actions.

5. Outline of Money Laundering

Money laundering means exchanging money or assets that were obtained criminally for money or other assets that are clean.  The clean money or assets don’t have an obvious link with any criminal activity. 

The following types of activities are considered to be money laundering and are prohibited

1. The conversion or transfer of property, including money, knowing or suspecting that such property is derived from criminal or certain specified unlawful activity for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
2. Conducting a financial transaction which involves criminal property;
3. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, ownership or control of criminal property;
4. The acquisition, possession or use of criminal property;
5. Promoting the carrying on of unlawful activity;
6. Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.

The broad definition of money laundering means that anybody could be in violation of the law if they become aware of, or suspects, the existence of criminal property within the business and becomes involved in or continues to be involved in a matter which relates to that property being linked to the business without reporting their concerns.

6. Red Flags
   • Where any suspicions arise that criminal conduct may have taken place involving a customer, colleague or third party, you should consider whether there is a risk that money laundering has occurred or may occur.
   • Examples of red flags to be reported include:
   • • A customer provides insufficient, false or suspicious information or is reluctant to provide complete information
   • • Methods or volumes of payment that are not consistent with the payment policy or that are not customarily used in the course of business.
   • • Orders or purchases that are inconsistent with the customer’s trade or business
   • • Payments to or from third parties that have no apparent or logical connection with the customer transaction
   • • Overpayments followed by directions to refund a payment, especially if requested to send the payment to a third party
   • • Any customer for whom you cannot determine the true beneficial owner
   • •Structuring transactions to avoid government reporting or record keeping requirements
   • • Unexpected spikes in a customer’s activities
7. Compliance controls

Management is responsible for ensuring that the business has a culture of compliance and effective controls to comply with laws and regulations to prevent, detect and respond to money laundering and to communicate the serious consequences of non-compliance to employees.

8. Employee Responsibility

They have the obligation to read and follow this policy, to understand and identify any red flags that may arise in business activities and to escalate potential compliance concerns.

9. Due Diligence and Record Keeping

This company has a policy to carry out due diligence at the outset of any business relationship and, if necessary, where any red flags arise subsequently on our suppliers, distributors, counterparties, agents and any person with whom we have an established business relationship that will involve the transfer to or receipt of funds, so we can be satisfied that they are who they say they are and so that we can ensure that there are no legal barriers to working with them before transactions occur.  Record-keeping is an essential component of the audit trail required to assist in any investigation.  Records must be maintained as evidence and ongoing monitoring undertaken.

10. Non-compliance

Any employee or contractor, who violates this policy may be subject to appropriate disciplinary action, independently from potential other penalties resulting from their behaviour.