1. Opulent Gold Group – Anti-Money Laundering (AML) Compliance Policy

Purpose

Opulent Gold Group (“OGG”) maintains this Anti-Money Laundering (AML) Compliance Policy to ensure full adherence to the Bank Secrecy Act (BSA), USA PATRIOT Act, and applicable FinCEN regulations governing dealers in precious metals, stones, or jewels (DPMS). The policy safeguards the integrity of the financial system by detecting and preventing money laundering, terrorist financing, and other illicit financial activity.

Policy Statement

OGG is committed to conducting all business activities with transparency, integrity, and in strict compliance with U.S. law. We maintain a written, risk-based AML program approved by senior management and reviewed annually.

Key Program Components

1. Compliance Officer: A designated AML Compliance Officer oversees daily operations of the program, ensuring training, oversight, and adherence to FinCEN’s DPMS Rule.
2. Risk Assessment: OGG continuously evaluates risks arising from product types (gold, silver bullion, numismatic coins), delivery channels (online, phone, and depository shipments), payment methods, and geographic locations.
3. Customer Due Diligence: The company verifies the identity of each customer and identifies the beneficial owners of all accounts prior to establishing a relationship.
4. Recordkeeping & Reporting:

Maintain customer and transaction records for a minimum of five years.

File IRS Form 8300 for any cash payments exceeding $10,000 in one or related transactions.

Report any suspicious activity to law enforcement or the company’s processor/custodian partners, as applicable.

1. Transaction Monitoring: OGG reviews transactions for patterns of structuring, third-party payments, or other red flags (e.g., unusually large purchases inconsistent with customer profile).
2. OFAC Sanctions Screening: All customers are screened against the Office of Foreign Assets Control (OFAC)list before transactions are processed.
3. Training: All employees receive annual AML training covering red flags, reporting procedures, and confidentiality obligations.
4. Independent Testing: OGG’s AML program is independently reviewed each year by a qualified third party to ensure effectiveness.

Non-Compliance

Any employee or affiliate found violating this policy may face disciplinary action, up to and including termination or referral to regulatory authorities.

Contact

Questions or concerns about this AML Policy should be directed to:
AML Compliance Officer – Opulent Gold Group
620 Newport Center Drive, Suite 1100, Newport Beach, CA 92660