AML and Compliance Statement

01Commitment

NewEarth Commodities does not facilitate money laundering, terrorist financing, sanctions evasion, tax evasion or trade in unlawfully sourced metal. Every party is verified before a transaction file is opened, and verification continues throughout the transaction.

This statement describes our own procedure. It is not a claim to hold any licence, registration or regulatory authorisation.

02Customer due diligence

• Identification of the applicant, the contracting entity, its directors, trustees and ultimate beneficial owners.
• Corporate records, mandates and evidence of authority to transact.
• Buyers: client information sheet, proof of funds and source of funds evidence, and confirmation from the holding institution where required.
• Sellers: title and origin documentation, export and licensing evidence, assay and custody records.
• Enhanced due diligence where the party, jurisdiction, structure or transaction size presents elevated risk.

03Screening and monitoring

• Sanctions, politically exposed person and adverse media screening of parties and beneficial owners.
• Ongoing monitoring for changes in ownership, control, jurisdiction or transaction pattern.
• Segregation of duties on payment release: preparation, approval and completion must be performed by three separate authorised officers.
• An append-only audit history recording every milestone and field-level change.

04Grounds for refusal or suspension

The desk will decline or halt a transaction where documentation cannot be verified, where the source of funds or source of product cannot be evidenced, where a party appears on a sanctions list, where the structure conceals the beneficial owner, or where the transaction otherwise presents unacceptable risk. No explanation of a compliance decision is owed beyond what the law permits us to give.

05Reporting

Where the desk is legally required to report a suspicion to a competent authority, it will do so, and may be prohibited by law from informing the party concerned.

06Compliance contact

Compliance matters: commodities@newxearth.com, +27 61 586 9195.