Sanctions Policy

Global Gold Verification Platform ("GGVP"), operated by PickNGotech Ltd (UK Company No. 16829327), maintains a zero-tolerance position on sanctions violations. This policy applies to all employees, contractors, verified partners, buyers and sellers interacting with the platform, regardless of the location of the transaction or the parties.

We monitor and apply, at minimum, the following sanctions frameworks:

• United Kingdom — Office of Financial Sanctions Implementation (OFSI), HM Treasury Consolidated List.
• European Union — EU Consolidated List of Persons, Groups and Entities subject to EU Financial Sanctions.
• United Nations — UN Security Council Consolidated Sanctions List.
• United States — OFAC Specially Designated Nationals (SDN) and Sectoral Sanctions Identifications (SSI).
• Other national lists where relevant to a transaction's jurisdiction (e.g. SECO, DFAT, OSFI).

Every individual, legal entity, ultimate beneficial owner (UBO), bank, refinery, vault, logistics carrier and vessel involved in a transaction is screened at onboarding and on a continuous basis. Screening covers name matches, aliases, date of birth, jurisdiction of incorporation and connected parties. List updates are ingested daily and re-screened automatically against the active portfolio.

GGVP will not facilitate transactions involving, originating from, or routing through comprehensively sanctioned jurisdictions. Transactions touching higher-risk jurisdictions identified by FATF, OECD or our internal risk model are subject to Enhanced Due Diligence (EDD) and senior compliance sign-off before any verification record is issued.

Any potential match — whether full or partial — is treated as a positive until cleared. The transaction is paused immediately, the match is escalated to the Money Laundering Reporting Officer (MLRO), and no documents, certificates or releases are issued during the review. Confirmed matches result in immediate termination of the engagement and, where required, reporting to the relevant competent authority.

Where a counterparty is identified as a designated person under UK financial sanctions, GGVP will report to OFSI in accordance with UK regulations and will not facilitate any further activity for that counterparty. Equivalent reporting will be made to other competent authorities where required by the relevant regime.

Employees, partners and platform users must not, directly or indirectly:

• Engage in transactions intended to circumvent or evade sanctions.
• Provide false, misleading or incomplete information to defeat screening.
• Use intermediaries, shell entities or jurisdictions to obscure ownership or origin of gold.
• Process transactions involving designated persons, restricted vessels or embargoed jurisdictions.

Overall responsibility for sanctions compliance sits with the MLRO, who reports to senior management. All staff and verified partners receive sanctions training at onboarding and at least annually thereafter. This policy is reviewed at least annually and updated whenever a relevant regime changes materially.

To report a sanctions concern or request guidance: