A2B GOLD FZCO

KYC and AML Policy

Last Updated: September 6, 2026

Our commitment

A2B GOLD FZCO, trading as A2B GOLD, is committed to preventing money laundering, terrorist financing and proliferation financing in its precious-metals trading activities. We apply the UAE’s applicable financial-crime requirements, including Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, as amended.

This policy describes our approach to customers, suppliers and other counterparties. A2B GOLD retains responsibility for compliance. Our designated Compliance Officer oversees the assessment and reporting of suspicious activity to the competent authorities as required by law.

Knowing our counterparties

Before starting a business relationship, we obtain and assess information about the counterparty, its business and the purpose of the proposed transactions. The documents requested depend on the counterparty and the risks involved. They may include identification, registration and licensing documents, addresses, ownership and control information, and evidence that representatives are authorised to act.

We identify beneficial owners and take reasonable measures to verify their identities. For legal entities, this includes the natural persons with ultimate controlling ownership of 25% or more. Where there is doubt about the beneficial owner identified through ownership, or no natural person exercises control through ownership, we identify control through other means. If neither route identifies a natural person, the applicable rules require identification of the relevant senior management person or persons. A percentage threshold alone does not settle every ownership structure.

We request source-of-funds information during onboarding to understand the origin of funds expected in the proposed transactions. Additional information, including source-of-wealth information, may be required by the circumstances or applicable law.

Screening and higher-risk relationships

Our checks address applicable sanctions, politically exposed persons and relevant adverse information. UAE targeted financial sanctions include the UAE Local Terrorist List and the United Nations Consolidated List. Other sanctions requirements are considered where applicable. Beneficial-ownership identification thresholds do not replace the separate ownership and control rules for sanctions.

We apply additional due diligence where the risk or law requires it. High-risk relationships require appropriate approval by A2B GOLD. We do not proceed where required due diligence cannot be completed or where a transaction or relationship is prohibited.

Monitoring and responding to concerns

We check incoming payments against the agreed transaction and the counterparty information collected during onboarding. Counterparty information is reviewed periodically in proportion to risk, and new information or concerns can require further review. Counterparties are expected to provide accurate information and tell us about material changes.

Where a serious compliance or sourcing concern is identified, we pause the affected transaction or business relationship while our Compliance Officer assesses it. We proceed only once the concern has been addressed to satisfy applicable legal and regulatory obligations.

Required sanctions measures, including freezing, restrictions on making funds available and reporting, apply independently of any attempt to resolve a concern. Suspicious activity is reported to the UAE Financial Intelligence Unit or other competent authorities as required. Legal restrictions may prevent us from explaining a report or action to a counterparty.

Records and privacy

We retain KYC and related compliance records for the periods required by applicable law. Covered due-diligence records are subject to a minimum five-year period measured from the latest applicable legal trigger. This can be the end of the relationship or a later account closure, occasional transaction, supervisory inspection, investigation or final court judgment. Other applicable retention obligations may also require preservation.

We use access controls and other safeguards to protect these records. Personal-data handling and rights are explained in our Privacy Policy.

Training, review and contact

We are committed to providing staff compliance training in accordance with applicable legal and regulatory requirements. We review this policy when changes in requirements, our activities or identified risks make an update necessary.

Privacy requests and compliance or sourcing concerns can be sent to compliance@a2bgold.com. We handle concerns confidentially, subject to disclosures needed to assess and address them or meet legal obligations. We prohibit retaliation against anyone who raises a concern in good faith.

Related policies: Supply Chain and Anti-Bribery.