KYC & AML Compliance Policy

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Effective Date: May 1, 2025

IGOLDEN TRUST TRADING OF RAW GOLD AND PRECIOUS METALS CO. LLC (“IGTT”)

At IGTT, we are firmly committed to ensuring full transparency, integrity, and compliance with global regulatory frameworks, including Know Your Customer (KYC), Anti-Money Laundering (AML), and Combating the Financing of Terrorism (CFT) requirements.

1. Purpose and Scope

This policy outlines the procedures we follow to verify the identity of our clients and partners, prevent our operations from being misused for financial crime, and ensure compliance with international sanctions laws.

2. Declarations of Compliance

a) Geographic Exclusivity

IGTT strictly limits its operations — including the sourcing, trading, and sale of raw gold and precious metals — to jurisdictions outside the Russian Federation and the Republic of Belarus.

Our primary markets include the Middle East, Africa, Europe, and Asia, and we maintain no operational, legal, or financial ties to Russia or Belarus.

b) Transaction and Counterparty Restrictions

We do not and will not:

 •  Initiate or receive payments from or to any financial institution, company, or individual located in Russia or Belarus.

 •  Enter into business relationships with suppliers, clients, or service providers incorporated in or operating from those jurisdictions.

 •  Trade in goods or assets originating from or destined for Russia or Belarus.

c) Sanctions Compliance

IGTT operates under a zero-tolerance policy for sanctions violations.

We comply with all applicable international sanctions regimes and conduct screening of all counterparties against the following lists:

 •  United Nations (UN)

 •  United States Office of Foreign Assets Control (OFAC)

 •  European Union (EU)

 •  United Kingdom (UK)

3. Customer Due Diligence (CDD) Procedures

We apply a risk-based approach (RBA) to due diligence. The level of verification depends on the risk profile of the client or transaction.

For Companies:

 •  Certificate of incorporation, memorandum/articles of association.

 •  Proof of registered address (utility bill or bank statement, not older than 3–6 months).

 •  Identification documents and verification of directors and UBOs (holding ≥25% ownership).

For Individuals (UBOs / Key Persons):

 •  Full name, nationality, date of birth, and address.

 •  Valid passport or government-issued ID.

 •  Proof of source of funds or wealth (bank statements, tax documents, etc.).

4. Transaction Monitoring & Reporting

 •  Ongoing Monitoring: We continuously monitor client transactions for unusual or suspicious activity, using both automated tools and manual oversight.

 •  Suspicious Activity Reports (SARs): In accordance with legal requirements, we report any suspicious behavior to the relevant authorities. Clients may not be notified if such notification is prohibited by law.

5. Data Retention & Confidentiality

 •  All KYC records and transactional data are retained for a minimum of seven (7) years after the end of the business relationship.

 •  Data is stored securely and is accessible only to authorized compliance personnel.

6. Training & Internal Controls

 •  All staff undergo annual AML/CFT training to identify risk indicators (“red flags”) and follow proper escalation procedures.

 •  Internal policies and systems are regularly reviewed through audits to ensure continued effectiveness and alignment with evolving global standards.

7. Source of Funds & Business Legitimacy

All capital and operational funds at IGTT originate from legitimate, transparent, and non-sanctioned sources.

The Ultimate Beneficial Owner (UBO) of the company is not a Politically Exposed Person (PEP) and is not subject to any sanctions. The company’s international business model is fully compliant and free from geopolitical risk exposure.

8. Transparency & Cooperation

IGTT is committed to full transparency with regulators, banks, and stakeholders upon request.

IGTT is dedicated to ethical conduct, regulatory transparency, and long-term business integrity.

This policy reflects our core values and our commitment to mitigating financial crime risk while fostering responsible trade in precious metals.