Anti-Money Laundering Policy

Global Gold Verification Platform ("GGVP"), operated by PickNGotech Ltd (UK Company No. 16829327), is a verification and deal-facilitation platform for international gold transactions. We do not custody, store, receive or transmit client funds, and we do not take title to physical gold. This Anti-Money Laundering ("AML") Policy describes the controls we apply to prevent our platform from being used for money laundering, terrorist financing, proliferation financing or sanctions evasion.

Our AML programme is designed in alignment with:

• The UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended).
• The Proceeds of Crime Act 2002 and the Terrorism Act 2000.
• UK, EU, UN and OFAC sanctions regimes.
• FATF Recommendations and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
• LBMA Responsible Gold Guidance principles applied to counterparty screening.

We apply a risk-based approach to every counterparty and transaction. Risk is assessed across customer type, geography, transaction value, source of funds, source of gold and delivery route. Higher-risk profiles trigger Enhanced Due Diligence (EDD), additional documentary evidence and senior compliance sign-off before any verification record is issued.

Before any party is admitted as a verified buyer or seller, we perform:

• Identification and verification of natural persons (government-issued ID, proof of address).
• Identification and verification of legal entities (incorporation documents, registers, ownership chart).
• Identification of Ultimate Beneficial Owners (UBOs) at or above 25% ownership or control.
• Politically Exposed Person (PEP), sanctions and adverse-media screening on an ongoing basis.
• Verification of legal capacity to buy, sell or represent the gold being transacted.

Full details are set out in our KYC Policy.

For every transaction facilitated through the platform, both buyer and seller must evidence the source of funds and, where relevant, source of wealth. Acceptable evidence includes bank statements, audited accounts, sale agreements, mining or refining records and other documentation appropriate to the counterparty's profile.

We screen all counterparties and connected parties against UK (OFSI), EU, UN and OFAC sanctions lists at onboarding and on a continuous basis. Transactions involving sanctioned individuals, entities, vessels, or restricted jurisdictions are refused. Any potential match is escalated immediately to the Money Laundering Reporting Officer (MLRO).

All staff, partners and verified professionals are required to report any suspicion of money laundering or terrorist financing internally without delay. The MLRO assesses every internal report and, where appropriate, submits a Suspicious Activity Report (SAR) to the UK National Crime Agency (NCA). Tipping-off is strictly prohibited.

Identification data, transaction records, due-diligence evidence and internal reports are retained for at least five (5) years after the end of the business relationship or the date of the transaction, in line with UK MLR 2017.

Staff and verified partners receive AML training appropriate to their role at onboarding and on a recurring basis. Overall responsibility for the AML programme sits with the MLRO, who reports to senior management and reviews this policy at least annually.

Questions about this policy or to report a concern: