Responsible Gold Policy Statement
Paloma Precious DMCC is committed to the strict compliance of OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the supplement on Gold. We work together hand in hand with all local and international bodies to fight against interaction with any entity, governmental or non-governmental bodies that engages in forced labor, child labor, sexual violence, bribery or any elements of misrepresentation of the origin of minerals, taxes, fees and royalties paid to government for mineral processing.
We commit ourselves to uphold the best practices in the industry and adhere to highest moral and ethical standards in whatever we do. We also comply with our AML policy which is aligned with national and international regulations in this regard.
Implementation Of The Policy Statement
- Strict and efficient KYC procedures.
- Clear responsibilities and delegation of authority at all levels.
- Risk assessment system and continuous monitoring of transactions.
- Proper and detailed record keeping and maintenance of records for at least four years.
- Continuous staff training.
A self-functioning escalation system is put in place where by anyone in the supply chain or within the organization can report any irregularities to the management. These irregularities will include money laundering, suspicious transactions that could be related to financing of terrorism or suspicious sourcing of gold. If needed such incidents are further escalated to regulatory authorities.
Anti Money Laundering Policy
AML – Overview
Paloma Precious DMCC is committed in compliance to, and strict practice of all regulatory requirements including those related to Anti Money Laundering by UAE and other competent world bodies. We comply with the regulations of world bodies which collectively set and enforce standards for Anti-Money Laundering and Counter-Terrorist financing policies and programs such as FATF, UN, The EU, The Organization of American States – The office of Foreign Assets Control (OFAC) and the Local Regulatory Authorities such as Central Bank of the UAE.
In UAE, the Central Bank of the UAE or more specifically the Anti-Money Laundering and Suspicious Cases Unit (AMLSCU) of the Central Bank is the regulatory body requiring the institution of AML rules. Since 2001, the UAE Government (UAEG) has taken steps to better monitor cash flows through the UAE financial system and to cooperate with international efforts to combat terrorist financing. The UAE has enacted two laws that serve as the foundation for the country’s Anti Money Laundering (AML) and counterterrorist financing (CTF) efforts: Law No 4/2002, the Anti-Money Laundering law, and Law No. 1/2004, the counterterrorism law. Although the Anti-Money Laundering law criminalizes money laundering, it is administrative Regulation No. 24/2000 that provides guidelines for how financial institutions are to monitor for money laundering activity.
Paloma Precious AML Policy
Paloma Precious DMCC is fully committed to local and international rules and regulations for the prevention of Money Laundering (ML) and terrorism activities. Accordingly, we have taken the necessary procedural and control measures to provide our support in the fight against money laundering and the financing of terrorism. We are also committed to examining and maintaining our Anti-Money Laundering procedures and control on an on-going basis.
Account Opening and Customer Identification
A proper system is in place for opening of new customer/supplier account. Without on-boarding the new customer/supplier in compliance with the set procedures, no transaction is entertained. ‘Know Your Customer / Customer Due Diligence procedures and guidelines’ are scrupulously adhered to before opening any new account. The compliance department go through the documents submitted by the parties before approving the same and the approval of compliance department is mandatory for account opening. However, cash transactions by small customers for small investment bars are honored without the need of any account opening.
Establishment Of Ultimate Ownership
Ultimate beneficial ownership of corporates and other legal entities with whom we do transactions are established by of obtaining and verifying copies of trade licenses, company formation documents, export import licenses, passport copies and any other documents deemed necessary for this purpose.
Enhanced Due Deligence
Enhanced due diligence is conducted when transactions appear to be potentially suspicious. Concerned staff ensures to ask for additional identification documents or documentary proof in such cases.
Internal Reporting System
In case of suspicious transaction, such cases are reported on concurrent basis to the compliance department as part of Paloma Precious internal reporting system. The Compliance department in turn will conduct in-depth investigation, and take an appropriate action before reporting such transactions to Anti-Money Laundering Suspicious Case Unit (AMLSCU) at the UAE Central Bank.
Staff Training And Recruiting
Before appointment of each employee, the HR department conducts a due diligence and asks for references from previous employers or institutions. Once appointed, each employee is given basic understanding of AML rules and company policies in this regard. All employees are required and instructed to adhere to the established AML rules in this regard. Periodic and concurrent training is also available within the organization.
All records including, customer’s identification documents and related data, transaction data, and any other related documents are maintained and retained for a minimum of five years.