Anti-Money Laundering and Know Your Customer (KYC) Policy

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BullionMax, LP (“Company”) has implemented an enterprise-wide Anti-Money Laundering (AML) compliance program and Know Your Customer (“KYC”) verification procedures, which covers all of its subsidiaries and affiliates, and are reasonably designed to comply with applicable laws and regulations.

This Policy seeks to prevent, mitigate and take reasonable and appropriate steps to prevent persons engaged in illegal activity from utilizing the Company’s products and services, as well as the requirements of other laws and regulations to the extent in which they relate to the Company’s operations.  International and domestic regulations require the Company to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its users (“Customers”).  Compliance with both the letter and the spirit of the laws in the countries and jurisdictions in which the Company operates is one way we work to achieve this Policy. 

To help the United States government fight potential illegal activity we have developed and implemented a risk-based anti-money laundering and KYC program, procedures, internal controls and systems, which include, but are not limited to, the following:

• A customer identification program and procedures that include the identification and verification of the identity of beneficial owners of certain entity customers;
• Procedures, processes and systems to collect and refresh customer due diligence information; processes to assess risk at both the program and customer level;
• Procedures, processes and systems to monitor customer transactions and activity;
• Procedures, processes and systems to identify and report suspicious activity ; and
• Procedures, processes and systems to produce other required reports and keep required records.

This means when a Customer opens an account, the Company may ask for a Customer’s identification information (e.g., name, address, date of birth, driver's license, national identification, international passport, bank statement, utility bill; corporation, partnership, trust, or other legal entity information, and/or other information that will allow us to identify the Customer).  The Company will take steps to confirm the authenticity of documents and information provided by a Customer.  All legal methods for validating identification information will be used and the Company reserves the right to investigate certain Customers who have been determined to be risky or suspicious.

The Company reserves the right to verify a Customer’s identity in an on-going basis, especially when their identification information has been changed or their activity appears to be suspicious. In addition, the Company reserves the right to request up-to-date documents from Customers, even though they have passed identity verification in the past.

Customer identification information will be collected, stored, shared and protected strictly in accordance with the Company’s Privacy Policy and related regulations.

The Company cooperates fully with all law enforcement and regulatory investigations and inquiries.