Anti-money laundering and KYC policy

Our commitment

olaMac Security & Logistics does not accept being used for money laundering, terrorist financing, the financing of the proliferation of weapons of mass destruction or sanctions evasion. We comply with Law 9.613/1998, with the rules of the Financial Activities Control Council (COAF) applicable to persons who trade in or hold precious metals, and with Law 13.810/2019 on sanctions imposed by the United Nations Security Council, following a risk-based approach.

Know your customer

Before accepting metal we identify and verify every client: CPF, identity document and proof of address for individuals; CNPJ, corporate documents and the identification of directors, legal representatives and beneficial owners (individuals who ultimately own or control 25% or more) for legal entities. We may request information on the origin of your funds and metal and apply enhanced due diligence to higher-risk relationships, including Politically Exposed Persons (PEPs), their relatives and close associates.

Screening and monitoring

We screen clients against sanctions lists, including those of the UN Security Council, at onboarding and on an ongoing basis, and we monitor deposits, withdrawals, transfers and payments for transactions that are unusual for the relationship.

Transfers of ownership

Transfers of metal between clients are reviewed by our compliance team before they take effect. We may ask both parties about the purpose of the transfer and any price paid.

Origin of metal

We accept only metal from identifiable sources that meets our product specifications. We refuse metal whose lawful origin cannot be demonstrated, including metal that may originate from illegal mining or from conflict-affected and high-risk areas.

Record keeping

We keep identification and transaction records for at least 5 (five) years after the end of the relationship, as required by Law 9.613/1998.

Reporting to COAF

Where the law requires, we report transactions and proposals to COAF within the legal deadlines. We are prohibited from informing the persons concerned (article 11 of Law 9.613/1998) and may suspend or refuse transactions while we meet these obligations.

Periodic review

We review client information periodically and when documents expire. Please respond promptly to requests for updated information; we may be unable to continue the relationship or process transactions until it is provided.