Silver Stacker Bullion (Pty) Ltd

Registration Number: [Your Company Reg No] FICA Classification: Schedule 1, Item 20 (High-Value Goods Dealer)

1. Introduction and Commitment

Silver Stacker Bullion (Pty) Ltd ("the Company") is committed to the highest standards of transparency and integrity. As a dealer in precious metals and high-value goods in South Africa, the Company recognizes its obligation under the Financial Intelligence Centre Act (FICA) 38 of 2001 to prevent the business from being used for money laundering or terrorist financing activities.

2. Regulatory Framework

The Company operates as an Accountable Institution under Schedule 1, Item 20 of the FIC Act. This policy is designed to comply with:

• The Financial Intelligence Centre Act (FICA), 2001.
• The Prevention of Organised Crime Act (POCA), 1998.
• The Protection of Constitutional Democracy against Terrorist and Related Activities Act (POCDATARA), 2004.

3. Scope of Policy

This policy applies to all transactions conducted by the Company, specifically targeting transactions or series of linked transactions valued at R100,000.00 or more, as defined by the High-Value Goods Dealer (HVGD) framework.

4. Compliance Officer

The Board of Directors has appointed Lourens Rothmann as the designated AML Compliance Officer. Responsibilities include:

• Ensuring registration and reporting on the goAML portal.
• Maintaining the Risk Management and Compliance Programme (RMCP).
• Training staff on AML/CTF obligations.

5. Customer Due Diligence (CDD) / KYC

The Company shall not establish a business relationship or conclude a transaction with a client until their identity has been verified.

5.1 Standard KYC Requirements (Transactions ≥ R100,000)

For all transactions exceeding the HVGD threshold, the Company will collect:

• Natural Persons: Certified copy of Identity Document and Proof of Residence (not older than 3 months).
• Legal Entities: CIPC registration documents, proof of business address, and identification of ultimate beneficial owners (UBOs).

5.2 Second-Hand Goods Compliance

In accordance with the Second-Hand Goods Act, the Company will record the identification and physical address of every person from whom bullion or precious metals are purchased, regardless of the transaction value.

6. Prohibited Activities & "No-Cash" Policy

To mitigate risk, the Company enforces a Strict No-Cash Policy:

• No physical cash (banknotes/coins) will be accepted for sales.
• No physical cash payments will be made for purchases.
• All transactions must occur via EFT, Bank Transfer, or approved Digital Asset gateways to ensure a clear audit trail through the South African banking system.

7. Reporting Obligations

The Company will report the following to the Financial Intelligence Centre (FIC) via goAML:

• Suspicious Transaction Reports (STRs): When there is reason to suspect money laundering or unusual activity.
• Terrorist Property Reports (TPR): If any property in the Company’s possession is linked to a sanctioned entity.

8. Record Keeping

All KYC documentation and transaction records (including invoices, bank statements, and SAPS registers) shall be kept securely for a minimum of five (5) years from the date the business relationship is terminated or the transaction is concluded.

9. Sanctions Screening

The Company will screen clients against the UN Security Council Sanctions List and the South African Targeted Financial Sanctions list to ensure no dealings occur with prohibited individuals or entities.

10. Policy Review

This policy shall be reviewed annually by the Compliance Officer to reflect changes in South African legislation or the Company’s risk profile.

Signed: Lourens Rothmann Director & Compliance Officer

Date: [Current Date]