Anti-Money Laundering, Sanctions & KYC Policy

Why this matters

Precious metals, gemstones and high-value minerals can be attractive to criminals seeking to move or disguise illicit funds. As a dealer in precious metals and stones, Kursi Group is a Designated Non-Financial Business and Profession (DNFBP) under Nigerian law and takes its responsibilities seriously.

Legal framework

This policy implements our obligations under:

• the Money Laundering (Prevention and Prohibition) Act 2022;
• the Terrorism (Prevention and Prohibition) Act 2022;
• the Proceeds of Crime (Recovery and Management) Act 2022;
• the regulations and guidance of the Special Control Unit against Money Laundering (SCUML) and the Nigerian Financial Intelligence Unit (NFIU); and
• applicable United Nations, and where relevant other international, sanctions regimes.

Registration and compliance officer

Kursi Group companies that deal in precious metals and stones register with SCUML as required. We have appointed a Money Laundering Reporting Officer responsible for implementing this policy, overseeing screening, and filing reports with the NFIU.

Know Your Customer and Know Your Supplier

Before entering a business relationship, and periodically afterwards, we:

• identify and verify customers and suppliers, including company registration documents from the Corporate Affairs Commission or the equivalent foreign registry;
• identify beneficial owners — the individuals who ultimately own or control the entity;
• understand the nature and purpose of the relationship and the source of funds and, where appropriate, source of wealth;
• verify mineral titles and licences for suppliers through the Mining Cadastre Office and confirm the lawful origin of minerals;
• screen all parties and beneficial owners against sanctions lists and for politically exposed persons (PEPs) and adverse media; and
• apply enhanced due diligence to higher-risk relationships, including PEPs, cash-intensive suppliers, complex ownership structures and high-risk jurisdictions.

We will not establish or continue a relationship where we cannot complete due diligence.

Payment controls

• Export sales are settled through regulated banks, normally by confirmed Letter of Credit.
• We do not accept payments from unrelated third parties or in cash above the thresholds permitted by law and our internal procedures.
• Payments to suppliers are made only to bank accounts in the supplier's own name.

Monitoring and reporting

We monitor transactions for unusual patterns — such as prices out of line with the market, unexplained urgency, inconsistent documentation or unusual routing. Suspicious transactions are reported promptly to the NFIU in the form and timeline required by law, and cash and other threshold transactions are reported as required. Staff must never "tip off" anyone who is the subject of a suspicion or report.

Sanctions

We do not deal, directly or indirectly, with persons, entities or countries subject to applicable sanctions, and we screen counterparties, vessels and destinations before each export.

Record keeping

Customer due diligence records, transaction records and reports are kept for at least five years after the end of the relationship or transaction, or longer where the law requires, and are made available to the authorities on lawful request.

Training

Staff in trading, finance, procurement and compliance roles are trained at induction and at least annually.

Reporting concerns

Report suspicions to the Money Laundering Reporting Officer through Legal & Compliance, or through our confidential speak-up channel.