AML Policy

Anti-Money Laundering Program and Policy Summary

BSSG's commitment to compliance with federal regulations and financial crime prevention.

Purpose

BSSG prohibits the use of its services for money laundering or terrorist financing. This AML policy is in compliance with the U.S. Department of Treasury, Financial Crimes Enforcement Network (FinCEN), and the Bank Secrecy Act, as amended by the USA PATRIOT Act.

This program applies to purchases and sales of precious metals over $50,000 annually. The policy is reviewed and updated as necessary and is available to authorized government agencies upon request.

Key AML Policies

1. Cash Transaction Reporting

Cash transactions of $10,000 or more (single or related) are reported using IRS Form 8300.

2. Government Watch List Checks

Regular screening of government lists for non-cooperative countries, terrorism-related entities, and individuals.

3. Unusual Business Changes

Inquiries will be made into any significant changes in business behavior (e.g., payment/delivery method changes or third-party involvement).

4. Secrecy Requests

Requests for unusual secrecy are investigated.

5. Non-Cooperation

If a party refuses to provide required information, the transaction is reviewed by the Compliance Officer before proceeding.

6. Employee Training

Relevant employees are trained on AML laws and internal policies.

Customer and Business Partner Identification

BSSG collects standard identification for all customers and partners: name, address, contact info, and government-issued ID.

ID checks apply to all third parties involved in transactions.

BSSG ensures consistency in all ID records and investigates discrepancies.

Transaction Monitoring

All purchases/sales involving public members, foreign suppliers, or non-dealers require proper identification and must be paid via check or wire.

Third-party involvement requires explanation and approval.

All AML-compliance failures are referred to the Compliance Officer.

Red Flag Detection and Response

Red flags include:

Large or structured cash payments, use of money orders/travelers checks, third-party payments.

Reluctance to provide ID or business information.

Transactions inconsistent with industry norms or customer profiles.

When red flags are detected:

The Compliance Officer reviews the transaction.

A decision is made on whether to proceed.

Government Requests & SAR Filings

All government requests are directed to legal counsel.

Suspicious Activity Reports (SARs) are filed at the Compliance Officer's discretion and retained as part of AML records.

Documentation and Records

All AML compliance actions are documented and securely maintained separately from general business records.

The AML Program is supported by senior management and updated as needed.

Questions About Our AML Policy?

For questions regarding our Anti-Money Laundering policy or compliance procedures, please contact us.

Email us: [email protected]