Compliance
If we cannot show where it came from, we do not buy it.
An untraceable parcel is a problem for everyone who touches it after the seller, and we do not intend to be on that list. This page says what we check, what we refuse, and how to raise a concern.
Responsible sourcing
Gold moves through parts of the world where the difference between a legitimate parcel and a harmful one is a matter of documentation and judgement. The framework below is how that judgement is made systematic.
A management system
We have a written sourcing policy and one named person is responsible for it. Anyone, a supplier, a carrier, a competitor, can raise a concern, and it goes to that person.
Risk identification
Each supply chain is mapped as far back as it can be evidenced — the mine, the collection point, the refinery, the intermediaries — and assessed against the risks known to attach to that route.
Risk response
Each identified risk gets one of two answers, in writing: a mitigation plan with an owner and a date, or a refusal.
Independent review
The records are kept so that an auditor can check whether we actually did what the policy says.
Disclosure
We write up what we sourced, from where, and what we turned away, for the counterparties and authorities entitled to read it.
Where risk is identified, it is either mitigated under a documented plan, or the business is declined.
Anti-money-laundering
Precious metals dealers in the UAE sit inside the anti-money-laundering regime, with registration, reporting and record-keeping obligations that apply to every transaction.
- Counterparty identification
- Before we do business, the counterparty is identified and verified to the standard published on the onboarding page.
- Ongoing monitoring
- A relationship is reviewed for as long as it runs. When a pattern stops making commercial sense, we ask.
- Source of funds and goods
- We establish where the metal came from and where the money came from, from documents. Being told is not the same as being shown.
- Screening
- Counterparties and their beneficial owners are screened against applicable sanctions and watch lists.
- Suspicious activity
- Suspicious activity is reported to the competent authority. We are not permitted to tell a counterparty that a report has been made, and we will not confirm or deny it.
- Records
- Transaction and due diligence records are retained for the period required by UAE law and are available to regulators and auditors on request.
What we decline
Refused on sight, and no price changes it.
Metal without provenance
No paperwork, no trade. A higher offer makes us more careful.
Conflict-affected supply
Metal that may be financing armed groups is refused outright. So is metal from a route we cannot see into. We do not write mitigation plans for either.
Cash settlement
We settle through the banking system. Large cash transactions attract obligations and risks we will not take on.
Opaque ownership
If you will not tell us who owns you, we cannot onboard you.
Sanctioned parties and routes
Any match to an applicable sanctions regime ends the discussion.
Third-party payments
Funds arrive from, and are paid to, the counterparty to the trade. Payments routed through unrelated parties are refused.
Raising a concern
Raising a concern
If you believe metal in our supply chain has been sourced improperly, or that a person acting for Mintador has behaved improperly, tell our compliance contact. Concerns are recorded and investigated, and they can be raised in confidence.
The policy is not a secret.
The policy, the named officer and the audit route are sent on request.