Compliance is the product.
Independent of the trading desk.
Auremont’s compliance function reports independently of trading and holds a veto over onboarding and execution. No counterparty is approved, and no consignment moves, without a compliance sign-off recorded against the file.
The framework is built on UAE Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019, the FATF Recommendations, the OECD Due Diligence Guidance and the LBMA Global Precious Metals Code — applied uniformly across Dubai, Hong Kong and Geneva.
Four controls, applied to every file.
No counterparty is approved and no consignment moves until all four are signed off.
Programme and reporting
Risk-based programme with a designated compliance officer, staff training, transaction monitoring and suspicious-transaction reporting to the UAE Financial Intelligence Unit.
Counterparty identity
Corporate documents, trade licence, shareholding structure, ultimate beneficial ownership at 25 per cent and below where risk requires, and verified authorised signatories.
Source of funds and wealth
Documented source of funds and wealth, expected activity baseline, and enhanced measures for high-risk jurisdictions and politically exposed persons.
Origin assurance
OECD Annex II risk assessment at every producing site, with licence verification, production baselines and scheduled reassessment.
What a file must contain.
A counterparty file is complete only when every element below is present, verified and dated. Incomplete files are not traded against.
Identity
Trade licence, incorporation documents, board resolution and verified identification for directors, signatories and ultimate beneficial owners.
Screening
Sanctions, PEP and adverse-media screening against OFAC, EU, UK, UN and DFAT lists at onboarding and continuously thereafter.
Financial profile
Source of funds and wealth documentation, bank references and an expected activity baseline against which flows are monitored.
Risk rating
A written risk rating driving review frequency, transaction thresholds and the level of enhanced due diligence applied.
Sign-off
Approval recorded by the compliance officer independently of the trading desk, with the rationale retained on file.
Reviewable by a third party.
All trade, assay, transport, correspondence and due-diligence records are retained for no less than ten years and are made available to accredited refiners, auditors and competent authorities on request. Financial statements are audited annually by an external firm, and supply-chain due diligence is assessed against the OECD Guidance and the LBMA Global Precious Metals Code. Settlement is by wire in cleared funds only: we do not accept cash, bearer instruments or payment from third parties, and we do not settle to accounts held in a name other than the contracting counterparty.
Documents we issue.
AML/CFT policy
Programme summary, reporting lines and monitoring thresholds, issued to counterparties under NDA.
KYC & KYB pack
The document list and templates required to complete onboarding, issued at first contact.
Responsible sourcing report
Annual summary of site assessments, findings and remediation actions, independently assured.
Assay & origin dossier
Assay certificate, licence reference and chain-of-custody record issued with every consignment.