AML Policy

ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM | American Gold and Silver Plans

Adoption of Compliance Plan

The purpose of the AML compliance plan is to establish the general framework for combating money laundering, terrorism, corruption, and other financial crimes.

American Gold and Silver Plans is committed to regularly reviewing AML strategies and objectives and maintaining an effective AML program. We uphold high standards of AML compliance and require management, employees, and agents to adhere to these standards to prevent the misuse of our products and services for money laundering purposes.

Adherence to this policy is crucial for ensuring compliance with applicable anti-money laundering legislation. We are required and committed to adhering to minimum standards of anti-money laundering compliance based on applicable laws, regulations, and any additional standards from our regulatory supervisors, which clarify the main statutory duties imposed on our institution.

Employee Training

A key component of an effective compliance program is employee training. Minimum training must include how to identify suspicious activity and structured transactions, record-keeping, reporting requirements, verifying identification, and familiarity with anti-money laundering statutes. All employees are required to read this manual and sign a copy of the Acknowledgement of Employee Training, which will be retained in their personnel file or Anti-Money Laundering files.

Money Laundering Overview

Money laundering is defined as “the attempt to conceal or disguise the nature, location, source, ownership, or control of illegally obtained money.”

Three Stages of Money Laundering

There are three stages of money laundering. By using these stages, a person can make illegal funds appear to come from a legitimate source.

1. Placement:

• A person purchases money orders, traveler’s checks, prepaid cards, money transfers, etc., with funds obtained from a crime.

2. Layering:

• A person moves money from one financial institution to another and changes the form of the money through multiple transactions, making it difficult to trace the money to its original source.

3. Integration:

• Changing the money into a seemingly legitimate form (e.g., purchasing automobiles, businesses, real estate) that can later be sold.

Office of Foreign Assets Control (OFAC)

OFAC is part of the U.S. Department of the Treasury and is responsible for enforcing U.S. government sanctions against countries, organizations, and individuals. Sanctions programs typically involve blocking assets to further national security. Many sanctioned individuals (SDNs) are known drug dealers and terrorists. All U.S. entities are prohibited from conducting financial transactions with SDNs. A list of names of individuals is available on the U.S. Department of the Treasury website.

Suspicious Transactions

Employees shall be trained to identify transactions that may involve the use of the dealer to facilitate money laundering or terrorist financing, including, but not limited to, transactions that involve:

• Unusual payment methods, such as large amounts of cash, multiple or sequentially numbered money orders, traveler’s checks, cashier’s checks, or payments from third parties.

• Unwillingness by a customer or supplier to provide complete or accurate contact information, financial references, or business affiliations.

• Attempts by a customer or supplier to maintain an unusual degree of secrecy with respect to the transaction, such as a request that normal business records not be kept.

• Purchases or sales that are unusual for the particular customer or supplier, or type of customer or supplier.

• Purchases or sales that are not in conformity with standard industry practices.

Employees shall do the following:

• Require appropriate customer identification for all transactions.

• Report all cash transactions above $10,000 using IRS Form 8300.

• Report suspicious transactions to appropriate governmental authorities without delay.

American Gold and Silver Plans shall always cooperate with and take guidance from the Financial Crimes Enforcement Network, the United States Department of the Treasury, the Internal Revenue Service, and other appropriate regulatory and enforcement agencies.

Designation of Compliance Officer

American Gold and Silver Plans agrees to formally designate a competent individual to serve as its Compliance Officer. The designated employee should hold a position of responsibility that allows them to implement an effective Anti-Money Laundering Compliance Program. The Compliance Officer, along with senior management, is responsible for ensuring ongoing compliance with all federal and state anti-money laundering laws and regulations. The Compliance Officer’s duties will include ensuring that the anti-money laundering program is implemented effectively, that the program is updated as necessary to reflect changes in risk assessment, statutory requirements, and further guidance issued by the Department of the Treasury, and that appropriate personnel is trained in accordance with the policy.

The Compliance Officer is also responsible for ensuring that a periodic review is conducted on the quality of the Compliance Program. This review may not be conducted by the Compliance Officer but should be performed by a senior-level employee or qualified professional who understands the requirements of an effective compliance plan.

Independent Review

A precious metals dealer is required by the USA Patriot Act to conduct an independent review of its compliance program. A senior-level employee of American Gold and Silver Plans, or another qualified party such as American Gold and Silver Plans’ attorney or accountant, may conduct the review. The designated Compliance Officer cannot conduct the review. Whoever conducts the review must be familiar with the Compliance Program and the anti-money laundering requirements for a precious metals dealer. The USA Patriot Act does not specify the frequency of the reviews, other than that they must be done commensurate with the dealer’s assessment of the money laundering and terrorist financing risks associated with its line of business. When making this assessment, the dealer should consider:

• The type(s) of products the dealer buys and sells, as well as the nature of the dealer’s customers, suppliers, distribution channels, and geographic locations.

• The extent to which the dealer engages in transactions other than with established customers or sources of supply, or other dealers subject to this rule.

• Whether the dealer engages in transactions for which payment or account reconciliation is routed to or from accounts located in jurisdictions identified by the Department of State as a sponsor of international terrorism or designated as non-cooperative with international anti-money laundering principles or procedures.

USA Patriot Act Anti-Money Laundering Compliance Program

The USA Patriot Act requires all precious metals dealers to adopt a written anti-money laundering compliance program that is reasonably designed to ensure proper record-keeping and reporting of certain transactions and to prevent your business from being used to launder money. Your anti-money laundering compliance plan must at a minimum include:

A. Internal Policies: Procedures and controls based upon the dealer’s assessment of the money laundering and terrorist financing risks associated with its line of business, including policies and provisions for complying with the applicable requirements of the Bank Secrecy Act. The dealer shall incorporate policies, procedures, and internal controls to assist in identifying transactions that may involve the use of the dealer to facilitate money laundering or terrorist financing, including provisions for making reasonable inquiries to determine whether a transaction involves money laundering or terrorist financing, and for refusing to consummate, withdrawing from, or terminating such transactions.

B. Designation of a Compliance Officer: Responsible for assuring that policies and procedures are followed, updated as necessary, training and education are provided, and reports are properly filed.

C. Ongoing Employee Training Program: Explains policies and procedures and teaches how to identify suspicious activity.

D. Independent Review of the Anti-Money Laundering Program: The review should take place as needed and be as thorough as necessary based on the risks of your business. The review can be performed by one of your employees, but not the Compliance Officer. This plan will provide the necessary information to be in compliance with the USA Patriot Act.