REGULATORY COMPLIANCE & ANTI-MONEY LAUNDERING (AML) POLICY
Last Updated: 16/03/2025
1. Introduction
Aurix Recovery Ltd. ("we", "us", "our") is committed to conducting business with integrity, transparency, and in full compliance with all applicable legal and regulatory requirements. As a company operating in the precious metals recovery and refining sector, we are subject to stringent compliance obligations, including anti-money laundering (AML) regulations, environmental laws, waste management standards, and ethical sourcing requirements. This policy outlines our approach to regulatory compliance and AML measures, ensuring we meet industry best practices while mitigating risks associated with financial crime and unethical practices.
2. Regulatory Compliance Framework
Aurix Recovery Ltd. operates in accordance with UK laws and international best practices to ensure responsible business conduct. Our compliance framework covers the following key areas:
2.1 Environmental & Waste Management Compliance
We comply with all UK environmental regulations, ensuring our gold refining processes adhere to sustainable and ethical practices. Our key commitments include:
- ✓Hazardous Waste Handling – Full compliance with the UK's Hazardous Waste Regulations, ensuring responsible disposal of refining by-products.
- ✓Trade Effluent & Emissions Control – Adherence to UK trade effluent discharge permits and use of built-in NOx scrubbers to minimise environmental impact.
- ✓REACH & COSHH Compliance – Safe chemical handling, storage, and reporting in line with UK REACH (Registration, Evaluation, Authorisation & Restriction of Chemicals) and COSHH (Control of Substances Hazardous to Health) Regulations.
- ✓Sustainable Sourcing – Ensuring all materials supplied to us are ethically sourced and legally obtained, in compliance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
2.2 Business Conduct & Ethical Standards
Aurix Recovery Ltd. is committed to operating honestly, transparently, and responsibly. We uphold:
- ✓Zero tolerance for bribery, corruption, and fraud in any form.
- ✓Supplier due diligence and verification to prevent unethical sourcing.
- ✓Fair and legal business practices, ensuring all transactions comply with UK financial laws.
3. Anti-Money Laundering (AML) Policy
As a business operating in the high-value precious metals sector, we recognise the importance of robust AML measures to prevent financial crime, fraud, and money laundering. Our AML policy is structured around the UK Money Laundering Regulations (MLR) 2017, the Proceeds of Crime Act (POCA) 2002, and the HMRC's AML guidance for high-value dealers.
3.1 Customer Due Diligence (CDD) & Know Your Customer (KYC) Procedures
To comply with AML laws, Aurix Recovery Ltd. requires all suppliers and business partners to undergo due diligence verification before engaging in transactions. This includes:
- ✓Identification & Verification – We collect and verify the identity of all suppliers using official documentation such as a valid passport, national ID, or business registration documents.
- ✓Beneficial Ownership Disclosure – For corporate entities, we require confirmation of the ultimate beneficial owners (UBOs) to ensure transparency.
- ✓Source of Materials & Funds – Suppliers must declare the origin of their materials and provide transaction records where necessary to confirm legitimacy.
- ✓Ongoing Monitoring – Regular risk assessments of transactions and supplier relationships to detect and prevent suspicious activity.
3.2 High-Risk Transactions & Enhanced Due Diligence (EDD)
We apply Enhanced Due Diligence (EDD) in cases where transactions pose a higher risk of money laundering, fraud, or financial crime. These include:
- ✓Large or unusual transactions that fall outside normal business activity.
- ✓Transactions involving politically exposed persons (PEPs).
- ✓Suppliers from high-risk jurisdictions as identified by the Financial Action Task Force (FATF).
- ✓Cash transactions above regulatory limits (though we primarily operate through bank transfers for transparency and security).
3.3 Suspicious Activity Reporting (SAR)
Aurix Recovery Ltd. is obligated to report any suspicious transactions that may indicate money laundering or other illicit activities.
- ✓All suspicious transactions will be reported to the UK's National Crime Agency (NCA) via a Suspicious Activity Report (SAR).
- ✓Employees and relevant stakeholders are trained to identify red flags and escalate concerns immediately.
3.4 Record-Keeping & Reporting
We maintain transaction records in accordance with UK AML laws to ensure compliance and audit readiness:
- ✓Retention of financial records, supplier due diligence documents, and transaction logs for a minimum of 5 years.
- ✓Regular internal compliance audits to assess and strengthen AML measures.
3.5 Penalties for Non-Compliance
Failure to comply with AML laws can result in severe consequences, including:
- ✓Immediate termination of business relationships with non-compliant suppliers.
- ✓Reporting of violations to regulatory authorities, which may lead to legal actions, fines, and criminal liability.
- ✓Company-wide compliance reviews to prevent future infractions.
4. Responsibilities & Enforcement
Aurix Recovery Ltd. ensures strict enforcement of its compliance and AML policies by:
- ✓Appointing a Compliance Officer responsible for overseeing AML practices and regulatory adherence.
- ✓Conducting regular compliance training for employees to detect and prevent financial crime.
- ✓Reviewing and updating policies periodically to reflect changes in legal requirements.
5. Amendments & Updates
Aurix Recovery Ltd. reserves the right to update this policy as required to ensure continued compliance with regulatory developments. Any updates will be posted on our website, and suppliers will be notified of significant changes where applicable.
6. Contact Information
For any compliance-related queries or to report concerns regarding AML practices, please contact:
Aurix Recovery Ltd.