1. Purpose
This policy sets out how Tess Van Ghert (TVG) prevents the firm from being used, knowingly or unknowingly, for money laundering, terrorist financing, or the evasion of financial sanctions.
Policy summary · v1.2
A plain-English summary of the AML/CFT framework operated by Tess Van Ghert. The full policy is held on file and provided to counterparties on request.
This policy sets out how Tess Van Ghert (TVG) prevents the firm from being used, knowingly or unknowingly, for money laundering, terrorist financing, or the evasion of financial sanctions.
It applies to every director, employee, agent, and contractor of TVG and to every transaction in which TVG acquires precious metal from a counterparty.
TVG maintains a written firm-wide risk assessment that addresses customer, product, geographic, channel, and transaction risk. Mitigations and controls are calibrated to the assessed risk.
Standard CDD is performed on every counterparty before establishing a relationship: identification, verification, beneficial ownership to applicable thresholds, and an understanding of the nature and purpose of the business relationship. Enhanced due diligence is applied to higher-risk relationships and to politically exposed persons.
Counterparties, beneficial owners, and connected parties are screened against applicable consolidated sanctions and watchlists at onboarding and on an ongoing basis. Any positive or potential match is escalated to the MLRO before further activity.
TVG documents the source of goods for every lot acquired and, where the risk profile requires it, the source of funds of the counterparty. Evidence is retained in the transaction file.
Activity is reviewed against the expected profile of the counterparty. Unusual activity is escalated and, where appropriate, reported to the relevant authority by the MLRO.
Records of CDD, transactions, and screening results are retained for the period required by applicable law and made available to regulators on request.
All relevant staff receive AML/CFT training on appointment and at least annually. Records of training are retained.
The MLRO is responsible for the day-to-day operation of this policy and reports to the board. The policy is reviewed at least annually and updated to reflect changes in law, regulation, or the firm's risk profile.
This is a summary and does not constitute legal advice. For specific questions about a contemplated transaction, contact the desk at info@tessvanghert.com.