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This document forms part of the Company’s AML/CFT framework and must be read alongside the AML/CFT Policy. It is designed to be HMRC inspectionready and operationally usable by staff.
This BWRA is maintained in accordance with Regulation 18 of the Money Laundering Regulations 2017 and documents the Company’s assessment of money laundering and terrorist financing risks.
- Identification of inherent risk
- Assessment of existing controls
- Determination of residual risk
- Annually
- Upon material business change
- Following regulatory updates or AML incidents
- Inherent Risk: High
- Controls: Full corporate CDD, beneficial ownership verification, EDD for higher-risk entities, senior management approval
- Residual Risk: Medium
- Inherent Risk: High
- Controls: Provenance checks, supplier due diligence, transaction traceability
- Residual Risk: Medium
- Inherent Risk: High
- Controls: Country risk assessments, sanctions screening, EDD
- Residual Risk: Medium
- Inherent Risk: High
- Controls: Source of funds checks, payment scrutiny, MLRO escalation
- Residual Risk: Medium
- Risk Inherent Risk: Medium
- Controls: Non face to face verification controls, additional documentation
- Residual Risk: Low–Medium
- Certificate of incorporation / business registration
- Registered office address verification
- Principal place of business
- Nature and purpose of the relationship
- Ownership and control structure
- Beneficial owners (25%+ ownership or control)
- Directors and authorised signatories verified
- Sanctions screening completed
- PEP screening completed
- Customer risk rating documented
EDD is required where higher risk is identified, including PEPs, high-risk jurisdictions, unusual trading patterns, or complex structures.
- Source of funds verification
- Source of wealth assessment (where relevant)
- Additional corporate documentation obtained
- Adverse media screening
- Senior management approval recorded
- Enhanced monitoring plan implemented
Staff must escalate concerns where indicators include:
- Requests for unusually rapid settlement or resale
- Circular or back-to-back trading
- Scrap metals with inconsistent or unclear provenance
- Mismatch between customer profile and transaction size
- Third-party payment requests
- Transactions involving high-risk jurisdictions
- All red flags must be escalated to the MLRO immediately.
The following documents are maintained and made available upon request:
- AML/CFT Policy
- Business-Wide Risk Assessment (BWRA)
- CDD and EDD files
- Customer risk assessments
- SAR and internal reporting logs
- AML/CFT training records
- Sanctions and PEP screening evidence
- Policy approval and review records
The Company operates a strict zerocash policy and does not accept or make cash payments under any circumstances.
As such, the Company does not meet the definition of a High Value Dealer (HVD) under Regulation 14 of the Money Laundering Regulations 2017 and is therefore not required to register with HMRC for AML supervision.
Notwithstanding this, the Company voluntarily applies robust AML/CFT controls proportionate to the risks associated with international precious metals trading. Approved by: Abdul Rehman Mirza Effective Date: 22.01.2026 Next Review Date: 22.01.2027
Gold Bank is committed to improving ethical, social, and environmental standards within the precious metals trading sector in London.
✓ We maintain a zero-tolerance approach to modern slavery and human trafficking in compliance with the Modern Slavery Act 2015, and we fully adhere to the UK Bribery Act 2010, ensuring integrity and transparency in all our business activities.
✓ We also operate in strict compliance with our Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy, which outlines our procedures for preventing financial crime and ensuring regulatory compliance. This policy is available to view on our website.