Anti-Money Laundering Policy

Policy for Royal Holding Group

1. Introduction
This Anti-Money Laundering (AML) Policy outlines the strategies and procedures established by Royal Holding Group (referred to as "the Company") to prevent the misuse of its lab diamond ecommerce platform for money laundering, terrorist financing, and other illicit activities. The Company is committed to upholding stringent compliance with relevant AML laws and regulations.


2. Policy Statement
Royal Holding Group is dedicated to maintaining the highest standards of integrity and accountability by preventing unlawful activities, including money laundering and terrorist financing. This commitment extends to transactions involving amounts exceeding $10,000 and to transactions of $5,000 exhibiting a pattern, which will be flagged as "suspicious activity" and subjected to AML checks. To achieve this objective, the Company has put in place a robust AML program, which encompasses the following core elements:


3. Customer Due Diligence (CDD) for High-Value and Patterned Transactions
The Company will conduct comprehensive customer due diligence (CDD) for all transactions exceeding $10,000 and for transactions of $5,000 showing a pattern. This process will involve the collection and verification of the following information:
Full legal name and contact details of the customer.
Valid proof of identity (government-issued identification, passport, driver's license, etc.).


Verifiable proof of address (utility bills, bank statements, etc.).
Clear source of funds for the transaction.
Enhanced due diligence (EDD) measures will be implemented for high-value and patterned transactions, which may entail additional verification steps and continuous monitoring.


4. Risk Assessment
Regular risk assessments will be conducted to identify and categorize potential money laundering and terrorist financing risks associated with transactions exceeding $10,000 and patterned transactions over $5,000. These assessments will consider variables such as transaction size, customer behavior, and geographic locations. Risk assessments will be periodically updated or as required.


5. Suspicious Activity Monitoring and Reporting
The Company will establish robust systems to monitor transactions over $10,000 and transactions of $5,000 displaying patterns indicative of money laundering or terrorist financing. Any detected suspicious activities will be promptly investigated, and if warranted, reported to the appropriate authorities in accordance with applicable laws.


6. Record Keeping
Comprehensive records of customer identification, transaction details for transactions exceeding $10,000, patterned transactions over $5,000, and actions taken in response to suspicious activities will be meticulously maintained. These records will be retained for the designated period as stipulated by relevant AML regulations.


7. Training and Awareness
All employees and relevant stakeholders will receive recurring AML training, focusing on transactions exceeding $10,000 and patterned transactions over $5,000. This training will ensure their comprehension of risks, regulations, and protocols pertaining to high-value and patterned anti-money laundering efforts. It will empower employees to identify and address suspicious activities effectively.


8. Compliance Officer
A designated Compliance Officer will oversee the execution of the AML program for transactions exceeding $10,000 and patterned transactions over $5,000. This officer will conduct regular evaluations and ensure ongoing compliance with AML laws and regulations.


9. Continuous Enhancement
Royal Holding Group is dedicated to the continuous enhancement of its AML program for high-value and patterned transactions. This commitment is driven by evolving risks, industry best practices, and regulatory updates. Regular reviews and refinements will be undertaken to ensure the effectiveness of AML policies and procedures.


10. Conclusion
By embracing this AML Policy, Royal Holding Group is actively contributing to global efforts against money laundering, terrorist financing, and other illicit financial activities. This policy underscores the Company's steadfast commitment to upholding transparency, integrity, and compliance in all its operations involving substantial monetary transactions and patterns.

 

Customer Due Diligence

Policy for High-Value Diamond Purchases

1. Introduction

The Royal Holding Group is dedicated to upholding the highest standards of integrity, transparency, and regulatory compliance in its operations. This Customer Due Diligence (CDD) Policy is specifically designed for transactions involving high-value diamond purchases exceeding $10,000. The policy outlines the procedures and processes undertaken to assess, verify, and monitor customers engaging in such transactions, in alignment with anti-money laundering (AML) and countering the financing of terrorism (CFT) regulations.


2. Objective

This CDD Policy aims to ensure that the Royal Holding Group conducts thorough due diligence on customers making high-value diamond purchases to identify and mitigate potential risks related to money laundering, terrorist financing, or other illicit activities. By implementing robust CDD measures, the company aims to preserve its reputation, financial integrity, and contribute to the overall security of the diamond trade.


3. Customer Identification and Verification

3.1. Customer Risk Classification: Customers making diamond purchases exceeding $10,000 will be subject to risk assessment to determine their potential risk level. Risk categories include low, medium, and high risk, assessed based on factors like the nature of the transaction, customer profile, and origin of funds.

3.2. Customer Identification: The company will collect accurate and current identification information from customers, including individuals and legal entities. This includes names, addresses, contact details, and government-issued identification documents.

3.3. Customer Verification: The Royal Holding Group will verify the authenticity of provided identification documents through reliable and independent sources. Enhanced due diligence (EDD) measures will be applied for high-risk customers, involving additional verification steps.


4. Beneficial Ownership

4.1. Identification of Beneficial Owners: For legal entities, the company will identify and verify beneficial owners who hold significant ownership or control over 25% or more of the entity's shares, voting rights, or management influence.

4.2. Verification of Beneficial Owners: The company will verify the identity of beneficial owners using appropriate checks and reviewing official documents and ownership records.


5. Ongoing Monitoring

5.1. Risk-Based Monitoring: Continuous monitoring of customer relationships will be carried out based on their risk classification. High-risk customers will undergo frequent and comprehensive monitoring, while lower-risk customers will be monitored periodically.

5.2. Suspicious Activity Reporting: The Royal Holding Group will promptly report any suspicious activities or transactions identified during monitoring to the relevant authorities in compliance with legal requirements.


6. Record Keeping

Comprehensive records of all CDD activities, including identification documents, verification results, risk assessments, and transaction records, will be maintained securely for the duration stipulated by regulations.


7. Training and Awareness

The company will provide regular training to employees to ensure their understanding of AML and CFT regulations and the importance of adhering to this CDD Policy.


8. Policy Review

This CDD Policy will be reviewed and updated as necessary to reflect changes in regulatory mandates, industry best practices, and the company's operational needs.

By following the principles outlined in this High-Value Diamond Purchases Customer Due Diligence Policy, the Royal Holding Group reaffirms its commitment to maintaining a secure and reputable position within the diamond industry, while actively contributing to global efforts against financial crime and illicit activities.

Date of Policy Implementation: 23/08/2023
Authorized by: Alex Jay
Position: Director