Anti-money laundering and KYC policy

Our commitment

olaMac Security & Logistics does not accept being used for money laundering, terrorist financing, proliferation financing or sanctions evasion. We comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Sanctions and Anti-Money Laundering Act 2018, following a risk-based approach.

Know your customer

Before accepting metal we identify and verify every client: an identity document and proof of address for individuals; company registration documents and the identification of directors and beneficial owners (individuals who ultimately own or control more than 25%) for organisations; and the trust deed, trustees, settlors and beneficiaries for trusts. We may ask about the source of your funds and metal and apply enhanced due diligence to higher-risk relationships, including politically exposed persons, their family members and close associates.

Screening and monitoring

We screen clients against the UK sanctions list maintained by the Office of Financial Sanctions Implementation (OFSI), and other applicable lists, at onboarding and on an ongoing basis, and we monitor deposits, withdrawals, 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 product specifications. We refuse metal whose lawful origin cannot be demonstrated, including metal that may originate from conflict-affected and high-risk areas.

Record keeping

We keep customer due diligence and transaction records for 5 years after the end of the relationship, as required by regulation 40 of the Money Laundering Regulations 2017.

Reporting

Where required, our Money Laundering Reporting Officer reports suspicions to the National Crime Agency and reports frozen assets and suspected breaches to OFSI. We are prohibited from telling anyone that a report has been made, and we may delay 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.