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Anti-Money Laundering Program and Policy

GENERAL STATEMENT OF PURPOSE

It is the policy of Buy Gold and Silver Safely to prohibit the use of our business or services for money laundering or terrorist financing.

This AML Program and Policy has been developed in conformance with the Requirements of rules promulgated by the U.S. Department of Treasury, Financial Crimes Enforcement Network, 31 CFR Part 1Q3, Section 130.140 c, under the Bank Secrecy Act as amended by the USA PATRIOT Act of 2001 (Pub.L.107-56) and is based on Buy Gold and Silver Safely assessment of the money laundering and terrorist financing risks associated with Buy Gold and Silver Safely transactions pertaining to covered goods.

Purchased in excess of $50,000 and sold in excess of $50,000 in any tax or calendar year.

This Program and Policy will be made available to the U.S. Department of Treasury or any other duly authorized government agency upon request.

Both this AML Program and Policy and Buy Gold and Silver Safely Risk Assessment have been reviewed by Senior Management of (Buy Gold and Silver Safely). Both this Program and the Risk Assessment may be updated from time to time This Program and Policy applies only to the purchase and sale of covered goods defined as precious metals (of an assay ¡in excess of 500 parts per thousand), precious stones and jewels, and finished goods of which 5C% of the value is derived from the precious metal, precious stones or jewels contained in or attached to such goods.

GENERAL POLICIES

  • I. It is the policy of Buy Gold and Silver Safely to comply with all cash reporting requirements for receipt of cash in a single transaction or in a series of related transactions in an amount of $10,000 or higher. In all such cases, an IRS Form 8300 will be completed in full and submitted to the appropriate government agency.
  • 2. It is the policy of Buy Gold and Silver Safely periodically to check all known government agency or agency sponsored lists of counties that have been found to be non-cooperative in anti-money laundering efforts and lists f countries suspected of supporting terrorism and list of individuals suspected of supporting terrorism or engaging in terrorist activity. The purpose of this activity is to determine whether any source of supply, distribution channel or individual associated with the business of Buy Gold and Silver Safely has been included on such lists.
  • 3. Any request from a business partner of Buy Gold and Silver Safely to alter its course of dealing with Buy Gold and Silver Safely will be the subject of reasonable inquiries designed to determine the reasons for the change im course of dealings. Changes in course of dealing includes, but is not limited to: change in payment (receivable or payee) methods or locations, change in delivery methods or locations, introduction of heretofore unknown third parties into the course of dealing, change in the chain of distribution.
  • 4. Any request from a business partner of Buy Gold and Silver Safely for an unusual degree of secrecy related to the transaction will be the subject of reasonable inquiries designed to determine the reasons for the high degree of secrecy.
  • 5. It is the policy of Buy Gold and Silver Safely that, when the person or company supplying or purchasing covered goods, evades or refuses to respond to reasonable inquiries to acquire information or explanations required for compliance with the Buy Gold and Silver Safely program, it is the policy of Buy Gold and Silver Safely to:
  • a) Refer the transaction to the Compliance Officer for assessment
  • b) Decide whether or not to engage in the transaction
  • 6. It is the policy of Buy Gold and Silver Safely to train all relevant employees regarding the laws and regulations pertaining to anti-money laundering requirements and the program and policy of Buy Gold and Silver Safely.

PART 1 — Identification of Customers and business Partners.

  • 1. It is the policy of Buy Gold and Silver Safely to acquire from a business partners engaged in selling to or purchasing covered goods from Buy Gold and Silver Safely, and from customers engaged in transactions using credit instruments (checks, wire transfers, etc.) standard identifying information. This information is to be maintained in written form.
  • 2. Government issued identification documents.
  • 3. Identification information has already been recorded for established business partners and customers and will be acquired in advance of opening new accounts.
  • 4. It is the policy of Buy Gold and Silver Safely to review all identification information for internal consistency — all identification information must be consistent for each supplier or business partner on all identification documents, or a reasonable explanation for the inconsistency has been provided.

The standard information to be acquired is:

  • 1. Name
  • 2. Address
  • 3. Telephone number 4 Fax number
  • 5. Government issued identification number (Social Security, Tax identification, passport, license, etc.)
  • 5. It is the policy of Buy Gold and Silver Safely to acquire the above mentioned identification information for any third party associated in any manner with any transaction for covered goods in which Buy Gold and Silver Safely engaged, including third party payers or payees, recipients, suppliers or senders of goods.
  • 6. It is the policy of Buy Gold and Silver Safely to acquire all required identification information from members of the public, foreign sources of supply or other non-dealers from whom we purchase or acquire precious metal, precious stones, jewels or finished goods, 50% of the value of which is comprised of the precious metal, precious stones or jewels contained in or attached to such goods
  • 7. it is the policy of Buy Gold and Silver Safely to periodically check all government agency or agency sponsored lists of persons suspected of engaging in criminal activity or countries that support terrorism or have been identified as non-cooperative in efforts to combat money laundering. It is the responsibility of the Compliance Officer to check these lists on a periodic basis and to review the transactions and business partners of Buy Gold and Silver Safely to determine if any of the countries, individuals or entities engaged in business or any transactions with Buy Gold and Silver Safely.
  • 8. In cases where any party to a transaction evades or refuses to respond to reasonable inquiries designed to identify the person or otherwise comply with the AML Program of Buy Gold and Silver Safely, it is the policy of Buy Gold and Silver Safely to:
  • a. Refer the transaction to the Compliance Officer for assessment
  • b. Decide whether or not to engage in the transaction

PART 2 – Monitoring Business Transactions

A. Purchases of covered goods from members of the public

  • 1. In cases where any party to a transaction evades or refuses to respond to reasonable inquiries designed to identify the person, it is the policy of Buy Gold and Silver Safely to:
  • a) Refer the transaction to the Compliance Officer for assessment
  • b) Decide whether or not to engage in the transaction B. Purchases or sales of covered goods to or from foreign sources of supply or other non-dealers (estate sales, US government-sponsored sales, bankruptcy trustees, auction houses, etc.)
  • I. All transactions involving purchases or sales to or from foreign sources of supply or other non-dealers require identification procedures as described above.
  • 2. Payment for all such purchases of covered goods are in the form of check, or wire transfer ONLY.
  • 3. No third party should be engaged in payment or supply or distribution channel for the item purchased or sold without an explanation from the foreign source of supply or other non-dealer of the identity and reason for involvement of the third party.
  • 4. It is the policy of Buy Gold and Silver Safely to inquire of all foreign- based sources of supply about the implementation of an AML program consistent with their local laws.
  • 5. In cases where any party to a transection evades or refuses to respond to reasonable inquiries designed to monitor the transaction or otherwise comply with Buy Gold and Silver Safely’s AML program, it is the policy of Buy Gold and Silver Safely to:
  • a) Refer the transaction to the Compliance Officer for assessment
  • b) Decide whether or not to n4age in the transaction
  • 6. Any request from business partner 1:0 3lter its course of dealing regarding transactions with Buy Gold and Silver Safely will be the subject of reasonable inquiries designed to determine the reasons for the change in course of dealings.

Changes in course of dealing includes, but is not limited to: change in payment (receivable or payable) methods or locations, change ¡n delivery methods or locations, introduction of heretofore unknown third parties into the course of dealing, change ¡n the chain of distribution.

  • 7. In cases where any party to a transaction evades or refuses to respond to reasonable inquiries regarding changes in course of dealing with Buy Gold and Silver Safely it is the policy of Buy Gold and Silver Safely to:
  • a) Refer the transaction to the Compliance Officer for assessment
  • b) Decide whether or not to engage in the transaction

PART 3 – Detecting and Responding To Red Flags”

  • I. It is the policy of Buy Gold and Silver Safely to detect and respond to red flags that might raise suspicion that a particular transaction or business partner or customer is engaging in activity designed to facilitate money Laundering or terrorist financing.
  • 2. When ‘red flags” are detected, it is the policy of Buy Gold and Silver Safely to:
  • a) Refer the transaction to the Compliance Officer for assessment
  • b) Decide whether or not to engage in the transaction The following general categories describe “red flags” which trigger the above referenced process re:

Unusual Payment Methods Unusual payment methods include but are not limited to:

. use of large quantities of cash . sequentially numbered money orders . travelers checks in large quantities . repeated use of cashiers checks . payments from third parties . any combination of the above Unwillingness By a Customer, Business Partner Or Supplier To Provide Complete Or Accurate Contact Information, Financial References Or Business Affiliations;

Activities under this category include but are not limited to:

. A business partner or customer evades or refuses to provide identification information . A business partner or customer evades or refuses to answer reasonable inquiries about a transaction . A business partner or customer requests an unusual degree of secrecy related to a transaction . A business partner or customer uses a fake identification document Purchases Or Sales That Are Unusual For The Particular Customer, supplier or Type Of Customer Or Supplier Activities under this category include but are not limited to:

. Change of payment methods . Requests for payment or delivery to a third party Purchases or Sales That Are Not In Conformity With Standard Industry Practices Activities under this category include but are not limited to:

. Requests for payments not to be recorded on the books and records of the company . Requests that goods not be entered into inventory records . Unusual quantities of goods ordered . Requests for an unusual degree of secrecy

PART 4 – Procedures For Responding To Treasury And Requests For AML

Information Requests For Information From Duly Authorized Government Agencies It is the policy of Buy Gold and Silver Safely to refer all requests from the U.S. Dept. of Treasury or any other duly authorized government agency to Buy Gold and Silver Safely legal counsel for response.

All requests for information from U.S. Dept. o’ Treasury or other duly authorized government agencies will be reviewed by the responsible employee within 28 working days of the original request from the government agency, or in conformance with the timetable provided by the government agency.

All responses to government agencies will be prepared in written form by the Compliance Officer/Legal Counsel and reviewed prior to submission by the Compliance Officer/Legal Counsel Voluntary Reporting of Suspicious Activity It is the policy of Buy Gold and Silver Safely to file Suspicious Activity Reports (SAR), when appropriate. Any employee may suggest to the Compliance Officer the filing of a SAR.

It is the determination of the CO whether or not to file a SAR.

Suspicious activity is defined as any activity conducted or an attempt to conduct any activity that an employee of Buy Gold and Silver Safely suspects or has reason to believe involves money from criminal activity, is designed to evade this AML Program and Policy or any provision of th3 AML regulations pursuant to the USA PATRIOT Act, appears to serve no legitimate business purpose and for which no available facts provide reasonable explanation. When such activity is detected, the CO will review the activity and determine whether or not to recommend the filing of a SAR. Legal Counsel! President/ CEO/another employee of Buy Gold and Silver Safely will review such determination.

A copy of SAR’s filed according to the provisions of Buy Gold and Silver Safely’s AML Policy and Program will be maintained with all other documents and records for AML compliance.

Part 5 — Documentation and Records of AVAL Compliance

It is the policy of Buy Gold and Silver Safely to document all compliance actions in connection with this program and policy.

It is the policy of Buy Gold and Silver Safely to maintain the records and documents associated with compliance with this AML Program and Policy. These records are to be maintained separately from the books and records of Buy Gold and Silver Safely.

It is the policy of Buy Gold and Silver Safely to ensure the security of the records of AML Compliance.

This document is the AML Compliance Program and Policy of Buy Gold and Silver Safely. It has been endorsed and supported by the senior management of Buy Gold and Silver Safely. It will be updated and amended as needed.