Effective date: 01 January 2026
Waymark Metals Limited (“Waymark Metals”, “we”, “us” or “our”) is committed to preventing money laundering, terrorist financing and sanctions breaches across all aspects of its business. This Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Policy (“Policy”) sets out the standards, controls and procedures adopted by Waymark Metals to protect the Group, its stakeholders and counterparties.
This Policy applies to Waymark Metals Limited and all subsidiaries, affiliates and connected companies operating in or from the United Kingdom, European Union, United Arab Emirates, United States, Saint Kitts & Nevis, the British Virgin Islands, Sierra Leone, Liberia and Guinea (Conakry) (together, the “Waymark Group”).
This Policy must be read together with the Waymark Metals Code of Conduct and Anti-Bribery and Corruption Policy.
1. Policy Statement and Standard of Compliance
Waymark Metals adopts a zero tolerance approach to money laundering, terrorist financing and sanctions violations.
We apply the UK AML and CTF framework as the minimum global standard across all operations, regardless of local law, and comply with all applicable requirements under:
- UK AML and Counter-Terrorist Financing legislation
- EU AML Directives and EU sanctions regimes
- UAE Federal AML and sanctions regulations
- United States sanctions administered by OFAC
- Applicable local laws in Saint Kitts & Nevis, BVI, Sierra Leone, Liberia and Guinea (Conakry)
Where standards differ, the most stringent requirement applies.
2. Scope and Application
This Policy applies to all:
- Directors, officers and employees
- Consultants, contractors and advisers
- Agents, brokers and intermediaries
- Joint venture partners and counterparties
- Suppliers and service providers
- Artisanal miners, aggregators and sellers of gold or other minerals
Compliance with this Policy is a condition of engagement with Waymark Metals.
3. Prohibited Activities
Waymark Metals strictly prohibits:
- Money laundering or attempted money laundering
- Terrorist financing or facilitation of terrorist activity
- Dealing with sanctioned individuals, entities, vessels or jurisdictions
- Structuring or disguising transactions to evade controls
- Use of cash or informal payment channels outside approved procedures
Any transaction suspected of involving illicit funds will be rejected or terminated.
4. Customer, Counterparty and Supplier Due Diligence
Waymark Metals conducts risk-based due diligence on all stakeholders, including but not limited to:
- Shareholders and investors
- Directors and senior management
- Contractors, consultants and agents
- Gold sellers, artisanal miners, aggregators and suppliers
- Transporters, refiners and logistics providers
Due diligence may include identity verification, beneficial ownership checks, sanctions screening, source of funds and source of wealth analysis, and ongoing monitoring.
Waymark Metals reserves the right to refuse to engage, suspend or terminate relationships where satisfactory due diligence cannot be completed.
5. Gold, Minerals and High-Risk Commodities Controls
The trading, sourcing and aggregation of gold and minerals is recognised as a high-risk activity for money laundering and sanctions exposure.
Accordingly:
- All gold and mineral purchases are subject to enhanced due diligence
- Source of material, ownership and chain of custody must be reasonably established
- Transactions lacking transparency or documentation are prohibited
- Cash transactions are strictly restricted and subject to approval
Waymark Metals will not purchase minerals where there is a reasonable risk of illicit origin, conflict financing or sanctions exposure.
6. Sanctions Compliance
Waymark Metals complies with all applicable sanctions regimes, including those imposed by:
- The Office of Foreign Assets Control (OFAC), United States
- United Kingdom sanctions authorities
- European Union sanctions authorities
- United Arab Emirates sanctions regulations
We do not engage in transactions involving sanctioned persons, entities, vessels, countries or territories, directly or indirectly.
Sanctions screening is conducted at onboarding and on an ongoing basis. Transactions may be delayed, blocked or rejected where sanctions risk is identified.
7. Politically Exposed Persons (PEPs)
Enhanced due diligence is applied to Politically Exposed Persons, their close associates and family members.
Approval from senior management is required before establishing or continuing any relationship involving a PEP.
8. Ongoing Monitoring and Transaction Review
Waymark Metals conducts ongoing monitoring of relationships and transactions to identify unusual, suspicious or high-risk activity.
Where required by law, suspicious activity reports will be made to the appropriate authorities.
9. Record Keeping
All due diligence, transaction records and compliance documentation are retained for the period required by applicable law and internal policy.
Records must be accurate, complete and readily available for regulatory review if required.
10. Whistleblowing and Reporting Concerns
Any suspicion of money laundering, terrorist financing or sanctions breaches must be reported immediately through internal compliance channels.
Reports may be made confidentially and without fear of retaliation. Retaliation against individuals who report concerns in good faith is strictly prohibited.
11. Investigations and Cooperation
Waymark Metals will investigate any suspected breaches of this Policy and will cooperate fully with lawful requests from regulators and law enforcement authorities.
12. Consequences of Breach
Breaches of this Policy may result in:
- Immediate suspension or termination of employment or engagement
- Termination of contracts or partnerships
- Reporting to regulatory or law enforcement authorities
Waymark Metals reserves all rights to protect its legal, regulatory and commercial interests.
13. Oversight and Responsibility
Senior management is responsible for oversight of AML, CTF and sanctions compliance. Ultimate accountability rests with the Board of Waymark Metals.
14. Policy Review
This Policy will be reviewed periodically and updated to reflect changes in law, regulation or risk profile.