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2. Introduction
Mahavir Bullion & Refinery Private Limited (“MBRPL” or “the Company”) is committed to conducting its business in a lawful, transparent and ethical manner. As a precious-metals refinery and bullion trading entity, the Company recognises that gold, silver and PGM are high-value products that can be vulnerable to money laundering, terrorist financing, fraud, smuggling and other financial crimes.
This Policy establishes the Company’s framework for preventing, identifying, assessing, monitoring, escalating and reporting money-laundering and terrorist-financing risks. It shall be read together with the Company’s Responsible Gold, Silver & PGM Sourcing Policy, KYC/Due Diligence SOP, Risk Mitigation Plan and other applicable controlled documents. -
3. Purpose
• Prevent the Company from being used to launder proceeds of crime or finance terrorism.
• Establish documented KYC procedures for suppliers, customers and other relevant counterparties.
• Apply a risk-based approach to identify higher-risk counterparties, transactions, products and geographies.
• Monitor transactions for unusual or suspicious activity and escalate/report suspicions as required by applicable law.
• Support RJC COP 2024 responsible-sourcing and KYC requirements.
• Ensure employees understand their AML/CFT responsibilities and know how to escalate concerns.
• Protect the Company, employees, counterparties and stakeholders from legal, financial and reputational harm. -
4. Scope
This Policy applies to:
• All MBRPL employees, including full-time, part-time, outsourced and contractual personnel whose roles may expose them to AML/CFT risks.
• All suppliers of gold doré, scrap/recycled precious metals, bullion and other COP RJC Scope Materials or inputs intended to become COP RJC Scope Materials.
• All customers, dealers and trading entities within the Company’s business relationships, subject to the RJC treatment of end consumers.
• Intermediaries, agents, transporters and logistics partners where relevant to the transaction or supply chain.
• Procurement, refining, processing, trading, storage, finance, sales and compliance activities.
• Third-party refining or processing arrangements and consignment arrangements involving COP RJC Scope Materials. -
5. RJC COP 2024 Requirements Addressed
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8. Risk-Based Approach
MBRPL shall assess AML/CFT risk using a documented, proportionate and risk-based methodology. Risk shall be assessed before establishing a relationship and monitored throughout the relationship. -
8.1 Counterparty Risk
• Legal and regulatory history.
• Beneficial ownership and control structure.
• Reputation and adverse media.
• Nature and legitimacy of business activity.
• Government, military or political affiliations where relevant.
• Unusual ownership, unexplained complexity or shell-company indicators.
• Quality and completeness of KYC information.
• AML/CFT controls maintained by the counterparty. -
8.2 Geographic Risk
• Countries identified as higher risk under applicable official sources.
• Conflict-Affected and High-Risk Areas (CAHRA).
• Weak AML/CFT regulatory environments.
• Countries or routes associated with illegal precious-metals movement or sanctions concerns. -
8.3 Product / Material Risk
• Gold doré from higher-risk regions.
• Scrap or recycled material with uncertain origin.
• Mixed or unverified precious-metal sources.
• Material processed or refined on behalf of a third party.
• COP RJC Scope Materials handled on consignment. -
8.4 Transaction Risk
• Large or unusual cash/cash-like payments.
• Structuring or splitting transactions.
• Over- or under-invoicing.
• Rapid turnover without a clear economic rationale.
• Circular or unnecessarily complex transactions.
• Third-party payments inconsistent with the relationship.
• Transactions inconsistent with declared business profile or expected activity.
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9. KYC / KYB Due Diligence
The Company shall document and apply KYC procedures to relevant suppliers and customers of COP RJC Scope Materials, products containing such materials, and other materials intended to be converted into COP RJC Scope Materials. -
9.1 Identity and Legal Existence
• Obtain and verify government-issued identification or reliable government/company records appropriate to the counterparty type.
• Record legal name, registered address, business address, contact information, date/country of incorporation and registration/tax identifiers as applicable.
• Obtain parent-company/subsidiary information and management structure where relevant.
• Understand the counterparty’s core business activity, including its material sources where relevant.
• Obtain financial information proportionate to risk. -
9.2 Beneficial Ownership and Principals
• Identify and record beneficial ownership and principals were triggered by risk assessment or applicable law.
• Verify beneficial ownership using reliable sources such as government/company records, declarations and appropriate third-party checks.
• Escalate unclear, concealed or inconsistent ownership structures for enhanced review. -
9.3 Sanctions and Screening
• Screen relevant counterparties and, where applicable, beneficial owners/principals against legally applicable sanctions and relevant government lists.
• Use appropriate additional screening sources identified in the Company’s KYC SOP, including adverse media and relevant regulatory/debarment information.
• Potential matches shall be investigated before onboarding or further processing where required.
• Confirmed prohibited matches shall be escalated immediately and handled in accordance with applicable law.
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10. Enhanced KYC for Refining, Processing and Consignment
Where MBRPL has mineral-processing or refining operations that extract COP RJC Scope Materials from input substances on behalf of a third party, or where the Company handles COP RJC Scope Materials on consignment, enhanced KYC shall be conducted commensurate with the nature, scale and purpose of the business relationship.
• Establish the identity and legitimacy of the contracting party and relevant upstream/source parties to the extent required by risk.
• Understand the source and nature of the input material and the reason for the third-party processing/refining or consignment arrangement.
• Verify ownership/control and relevant principals where triggered.
• Assess expected volumes, transaction patterns, payment arrangements and destination of output material.
• Obtain additional information where the source, ownership, transaction purpose or material flow cannot be satisfactorily understood.
• Document the enhanced KYC assessment, approval and any conditions imposed. -
11. Ongoing Due Diligence and Monitoring
• Review transaction patterns against the Company’s knowledge of the counterparty and its declared business.
• Monitor changes in ownership, management, business activity, country of origin, routes and expected transaction volumes.
• Check payments for legitimacy and consistency with approved arrangements.
• Investigate discrepancies between declared and actual weights, assay/purity, origin, invoices or other material information.
• Document red flags and escalation decisions.
• High-risk relationships shall undergo enhanced and periodic review at a frequency determined by the risk assessment; the existing practice of quarterly review for high-risk suppliers shall continue unless the KYC SOP establishes a more appropriate documented frequency. -
12. Prohibited / Restricted Transactions
The Company shall not knowingly engage in transactions involving:
• Anonymous or fictitious counterparties.
• Confirmed sanctions/prohibited parties.
• Shell companies without a legitimate business purpose.
• Undeclared or illegal mining or other unlawful material sources.
• Transactions designed to conceal beneficial ownership.
• Materially inconsistent or fraudulent origin documentation.
• Suspicious routing or unexplained intermediaries.
• Cash/cash-like arrangements prohibited by applicable law or Company controls.
• Transactions where required KYC cannot be satisfactorily completed.
Potentially prohibited transactions shall be escalated to the Principal Officer/Compliance Officer and, where appropriate, Senior Management. No employee shall bypass the approval or escalation process to complete a transaction.
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14. Suspicious Transaction Reporting and Escalation
• Employees shall immediately escalate suspicious activity to the Principal Officer or Compliance Officer.
• The Principal Officer shall analyse alerts, document findings and rationale, and determine whether a statutory report is required.
• Where required, Suspicious Transaction Reports or other reports shall be filed with the relevant designated authority in accordance with applicable law and prescribed procedures.
• Confidentiality shall be maintained and no employee shall disclose information in a manner that constitutes prohibited tipping-off.
• Internal records shall document the alert, investigation, decision, reporting status and follow-up, subject to legal confidentiality requirements. -
15. Cash and Cash-Like Transactions
The Company shall maintain records of all single or apparently linked cash or cash-like transactions at or above EUR 10,000/USD 10,000 or the threshold defined by applicable law, whichever is lower, and shall report such transactions to the relevant designated authority where required by law. The Company shall also comply with any stricter applicable legal restrictions on cash transactions.
The Finance and Compliance functions shall ensure that transaction aggregation and linked transactions are considered where required. -
16. Record Keeping
The Company shall maintain adequate KYC and AML/CFT records. RJC COP 12.1 requires records for at least five years or as long as required by national legislation, whichever is longer. MBRPL’s existing control is eight-year retention; this shall continue unless a longer legal or contractual requirement applies.
• KYC/KYB files.
• Beneficial ownership and principals’ records.
• Sanctions and screening results.
• Risk classifications and EDD records.
• Transaction and payment records.
• STR/SAR and other statutory reporting records.
• Internal alerts, investigations and decisions.
• Training attendance and content.
• Internal audit/review reports.
• Corrective-action and risk-mitigation records. -
17. Training and Awareness
• Induction AML/CFT training for relevant new employees.
• At least annual AML/CFT refresher training for relevant personnel.
• Role-specific training for sourcing, procurement, operations, finance, compliance and other exposed functions.
• Training on red flags, escalation, reporting obligations, confidentiality and tipping-off.
• Training records shall be maintained in the AML Training Register or equivalent controlled record. -
18. Internal Review and Assurance
• The Company shall conduct periodic internal AML/CFT reviews to evaluate effectiveness of KYC, screening, transaction monitoring, escalation, recordkeeping and training.
• Review findings shall be reported to Senior Management and significant findings shall be escalated to the Board.
• Corrective actions shall have responsible owners and target dates and shall be tracked to closure.
• RJC audit evidence shall be maintained and made available to the auditor as appropriate. -
19. Disciplinary Action and Non-Retaliation
Employees who deliberately violate AML/CFT requirements, ignore known red flags, fail to escalate suspicious activity or attempt to circumvent controls may be subject to disciplinary action, up to and including termination, and reporting to authorities where required.
The Company shall not retaliate against a person who raises an AML/CFT concern in good faith or participates in an investigation. -
20. Policy Review and Approval
This Policy shall be reviewed at least once every 12 months and additionally when there are changes in law, regulation, RJC requirements, material business activities, risk exposure, audit findings, significant incidents or material changes to the Company’s KYC/AML programme.
Changes shall be documented through the Company’s document-control process and approved by the Board or other authorized approving body. -
21. Related Controlled Documents
• Supply Chain Policy
• KYC / Due Diligence SOP
• Risk Mitigation Plan
• Anti-Bribery & Anti-Corruption Policy
• Human Rights Policy
• Grievance Redressal Policy
• Whistleblower Policy
• Security Risk Assessment Policy
• Supplier / Business Partner Code, when approved
• Product Integrity / Claims & Disclosure Policy, when approved -
For Mahavir Bullion & Refinery Private Limited
