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AML/KYC Policy  GoldLuxo

1. Purpose and Commitment

GoldLuxo is fully committed to preventing the use of its services for money laundering, terrorism financing, fraud, tax evasion, or any other illicit activity.
We comply with:

  • UK law: Proceeds of Crime Act 2002, Money Laundering Regulations 2017, Sanctions and Anti-Money Laundering Act 2018,

  • EU directives: 5th and 6th Anti-Money Laundering Directives (AMLD5/6),

  • USA: USA PATRIOT Act and Bank Secrecy Act (BSA), including regulations issued by the Financial Crimes Enforcement Network (FinCEN), particularly 31 CFR Part 1027 for Dealers in Precious Metals, Stones or Jewels,

  • FATF recommendations,

  • all other international standards applicable to cross-border financial activity.

GoldLuxo is determined to maintain the highest compliance standards worldwide.

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2. Definitions

  • AML – Anti-Money Laundering

  • KYC – Know Your Customer

  • CTF – Counter-Terrorism Financing

  • EDD – Enhanced Due Diligence

  • SAR – Suspicious Activity Report

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3. Scope of Application

This policy applies to:

  • all clients of GoldLuxo (natural and legal persons),

  • all transactions (purchase, custody, buy-back, or physical delivery of gold),

  • all employees, contractors, and agents acting on behalf of GoldLuxo.

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4. Customer Due Diligence (CDD)

GoldLuxo requires the following:

  • full identification of every customer,

  • valid government-issued photo ID (passport, ID card, or driver’s license),

  • proof of residential address (utility bill, bank statement not older than 3 months),

  • for legal entities: certificate of incorporation, ownership structure, beneficial owner identification.

Cash Transactions Prohibition: GoldLuxo does not accept cash payments under any circumstances. All transactions (purchases, custody, buy-backs, or delivery) must be conducted exclusively via verified bank transfers (SEPA, SWIFT, or equivalent secure methods).

No transactions will be executed without successful completion of KYC.

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5. Enhanced Due Diligence (EDD)

GoldLuxo applies stricter checks in the following situations:

  • politically exposed persons (PEPs) and their relatives/associates,

  • clients from high-risk jurisdictions,

  • complex ownership structures,

  • transactions exceeding €10,000 (or equivalent) within 30 days,

  • for US clients: transactions exceeding $10,000 USD (or equivalent), where specific FinCEN reporting obligations may apply (e.g., CTR/Form 8300).

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6. Prohibited Clients

GoldLuxo will not onboard or serve:

  • anonymous clients,

  • clients using third-party or unverifiable bank accounts,

  • clients from sanctioned jurisdictions (OFAC, UN, EU, UK lists),

  • clients engaged in gambling, arms trade, drugs, or any unlawful activities.

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7. Monitoring of Transactions

  • All transactions are monitored in real-time and retrospectively.

  • Automated and manual controls are applied.

  • Any unusual patterns (structuring, rapid inflows/outflows, inconsistent activity) will trigger review and possible reporting.

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8. Record Keeping

  • All KYC data, transaction records, and communication logs are retained for a minimum of 5 years after the end of the business relationship, or longer if legally required.

  • Records are securely stored and accessible only to authorized staff.

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9. Reporting Obligations

GoldLuxo is legally obliged to report suspicious activity:

  • United Kingdom / EU operations – Suspicious Activity Reports (SARs) are submitted to the UK Financial Intelligence Unit (FIU) within the National Crime Agency (NCA).

  • United States operations – SARs are filed with FinCEN under the Bank Secrecy Act (BSA).

Clients will not be notified of any report (prohibition of tipping-off).

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10. Responsibilities and Compliance Officer

GoldLuxo has appointed an AML/KYC Compliance Officer responsible for the implementation of this Policy, regular reviews, and reporting duties.

Compliance Officer: Viliam Rigo
Contact: compliance@goldluxo.com

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11. Staff Training

All employees and contractors receive ongoing AML/KYC training, covering:

  • identification and verification procedures,

  • detection of suspicious activity,

  • reporting lines and escalation,

  • sanctions lists and updates.

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12. Independent Audit

GoldLuxo’s AML/KYC program is subject to regular independent audit and review to ensure effectiveness and compliance with UK, EU, and US regulations.

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13. Cooperation with Authorities

GoldLuxo fully cooperates with law enforcement agencies, regulators, and supervisory bodies in all jurisdictions where it operates.

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14. Disclaimer

  • GoldLuxo is not a bank, investment firm, or FCA-regulated financial institution.

  • GoldLuxo does not accept or process cash payments. All client transactions are strictly limited to non-cash bank transfers.

  • This ensures that GoldLuxo is not classified as a High Value Dealer (HVD) under UK law and is not subject to cash transaction reporting obligations under the US Bank Secrecy Act (BSA).

  • However, under the USA PATRIOT Act and BSA, GoldLuxo qualifies as a “Financial Institution” (Dealer in Precious Metals) and complies with all FinCEN requirements.

  • Services are not protected by the Financial Services Compensation Scheme (FSCS), nor do clients have access to a financial ombudsman.

  • GoldLuxo does not provide investment advice. All transactions are carried out solely at the client’s discretion and risk.​

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15. Review and Updates

This AML/KYC Policy is reviewed at least once per year, or earlier if required by changes in law or business practices.

Issued and effective as of: 26 October 2025
Published on: www.goldluxo.com

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