CORPORATE ASSET RECOVERY DIVISION

Compliance

Our commitment to anti-money laundering, responsible supply chain governance, and counterparty due diligence across every precious metals transaction we undertake.

OUR FRAMEWORK

01 AML & CFT

Full compliance with the UK Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002.

02 Responsible Sourcing

Supply chain due diligence aligned to OECD Annex II Guidance for minerals from conflict-affected and high-risk areas, and to the LBMA Responsible Gold Guidance. Zero tolerance for conflict-linked, laundered, or illegally mined material.

03 KYC & Due Diligence

Mandatory Know Your Counterparty procedures for all supply relationships.

Organization for Economic Cooperation and Development


The Organization for Economic Cooperation and Development (“OECD”) is an association of governments that work with each other to promote economic growth, prosperity, and sustainable development. The OECD allows governments to work together to solve common problems, identify good practices and coordinate domestic and international policies.The OECD has issued its Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Guidance”). Its objective is to help organizations respect human rights and to avoid contributing to conflict-heavy jurisdictions. Accordingly, Tess Van Ghert has implemented internal policies that adhere to the OECD Guidance.

Financial Action Task Force


The Financial Action Task Force (“FATF”) is an inter-governmental body established by its member jurisdictions with the objective of setting standards and promoting the effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other threats related to the integrity of the international financial system. The FATF has developed a series of recommendations that are recognized as the international standard for the combating of money laundering, the financing of terrorism and proliferation of weapons of mass destruction. The FATF issued its 40 Recommendations (the “Recommendations”), a comprehensive and consistent framework of measures for combating money laundering and terrorist financing. Tess Van Ghert has implemented the Recommendations and has adopted internal know your client (KYC) due diligence procedures to safeguard against money laundering and terrorist financing.