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Fine Gold Jewelry & Precious Metals Co. is fully committed to preventing the misuse of its products and services for illegal activities. The company firmly believes that no customer relationship is worth compromising its dedication to combating Money Laundering (AML) and Countering the Financing of Terrorism (CFT). Our compliance policy is aligned with Kuwait Law No. 106 of 2013 on AML & CFT, its executive regulations, and international standards. It serves as a comprehensive guide for all employees, ensuring the business operates transparently and responsibly. We adopt a risk-based approach, implement robust AML/CFT controls across all operations, and utilize advanced technological systems to detect, monitor, and report suspicious activity.
A strict KYC and KYCC (Know Your Customer’s Customer) framework is applied across all transactions, regardless of the amount. Customer Due Diligence (CDD) is performed for all clients, and Enhanced Due Diligence (EDD) is applied where risks are identified. Verification of customer identity and beneficial ownership is based on reliable and independent documents.
Recording and maintaining full customer details. Keeping copies of customer identification documents (Civil ID or equivalent). Prohibiting cash payments exceeding 3,000 Kuwaiti Dinars. Accepting payments only through official banking channels (e.g., K-Net). Ensuring payment instruments are in the customer’s own name.
All transactions are continuously monitored to detect unusual or suspicious activity relative to the customer’s profile. First line of defense: trained employees who flag anomalies. Second line of defense: compliance officers who conduct further review and monitoring.
All employees are trained to recognize and escalate suspicious activities to the Compliance Officer, who reports to the Kuwait Financial Intelligence Unit (FIU) without delay. Reporting is conducted using official FIU forms and communication channels.
Fine Gold Jewelry & Precious Metals Co. maintains a dedicated Compliance Department led by a Compliance Officer who reports directly to senior management. The team is responsible for: Updating policies in line with regulatory changes. Monitoring payments and customer transactions. Screening against local and international sanction lists. Conducting investigations. Executing Enhanced Due Diligence (EDD). Filing suspicious transaction reports with the FIU.
The AML/CFT function is reviewed regularly by internal audit and independent external auditors to ensure continuous compliance with all laws and regulations.
Employees undergo comprehensive AML/CFT training within 30 days of joining. Annual refresher courses are mandatory. Specialized training workshops and seminars are conducted to keep staff updated on evolving AML/CFT risks and techniques.
All customer and transaction records are retained for a minimum of five years, in accordance with Article 11 of Law 106/2013. Confidentiality is strictly maintained, and data is made available only to supervisory authorities upon request.
To ensure compliance integrity, employees must: Have prior experience in handling financial or material transactions. Provide a clean criminal record before employment. Pass internal testing and interviews to demonstrate suitability.
Independent internal audit functions verify compliance with policies, including: Checking all invoices and transactions. Ensuring ID verification for each customer. Maintaining official registers and accounting books. Preparing accounts for independent review by external auditors.
An integrated electronic customer database is maintained, with complete purchase and sales histories. A barcode tracking system is implemented for every gold piece. Customer documents (Civil ID, bank details) are electronically archived. Daily, weekly, monthly, and annual transaction reports are generated for monitoring. Backup copies of all data are securely stored.
Any suspicious transaction or attempt, regardless of value, must be reported promptly to the FIU. Employees are trained to check updates on terrorism and money laundering sanction lists daily. If a customer appears on sanctions lists, service is immediately denied, and the case is escalated to the Ministry of Foreign Affairs’ Special Committee in accordance with UN Security Council resolutions.
Regular risk assessments are conducted to evaluate money laundering and terrorism financing risks. Risk findings are documented and submitted to supervisory authorities (Ministry of Commerce and Industry) when requested. Procedures are updated in line with the FIU’s published risk indicators.
Fine Gold Jewelry & Precious Metals Co. is committed to ensuring its business practices remain compliant with the latest Kuwaiti AML/CFT regulations and global standards. By enforcing strict monitoring, reporting, and training, we safeguard the integrity of our operations and contribute to the protection of the financial system.