Anti-money laundering and KYC policy

This English version is provided for convenience. In case of doubt, the German version prevails.

Our principle

olaMac Security & Logistics will not be used for money laundering, terrorist financing, proliferation financing or sanctions evasion. We comply with the obligations of the German Money Laundering Act (GwG) and observe the financial sanctions of the European Union and the United Nations, following a risk-based approach.

Customer due diligence

Before accepting metal we identify and verify every client: individuals by a valid official identity document and proof of address; companies by register extracts and identification of their representatives and beneficial owners (individuals who directly or indirectly hold or control more than 25%, section 3 GwG), including a check against the Transparency Register. We may ask about the origin of funds and metal and apply enhanced due diligence to higher risks, in particular politically exposed persons, their family members and known close associates (section 15 GwG).

Sanctions screening and monitoring

We screen clients against the sanctions lists of the EU and the United Nations at onboarding and throughout the relationship, and monitor deposits, releases, transfers and payments for activity that is 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 specifications. We refuse metal whose lawful origin cannot be demonstrated, in particular metal from conflict-affected and high-risk areas.

Record keeping

We keep identification and transaction records for at least five years after the end of the relationship (section 8(4) GwG).

Reporting

Where facts indicate money laundering or terrorist financing, we report to the Financial Intelligence Unit (FIU) (section 43 GwG). We may not inform the persons concerned (section 47 GwG) and may suspend or refuse transactions.

Ongoing review

We update client information periodically and when documents expire. Please answer requests promptly; otherwise we may be unable to continue the relationship or carry out transactions.