KYC/KYB Policy

1. Introduction

Marcellus Capital Group Limited ("Marcellus Bullion", "we", "our", "us") is committed to maintaining the highest standards of compliance with anti-money laundering (AML) legislation and regulations. This Know Your Customer (KYC) and Know Your Business (KYB) Policy outlines our procedures for verifying the identity of our clients.

Our KYC/KYB procedures are designed to comply with:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
• The Proceeds of Crime Act 2002
• The Terrorism Act 2000
• Financial Action Task Force (FATF) recommendations
• HM Treasury sanctions requirements

2. Customer Due Diligence (CDD)

We conduct Customer Due Diligence on all clients before establishing a business relationship or carrying out occasional transactions above applicable thresholds. CDD involves:

• Identifying the customer and verifying their identity
• Identifying beneficial owners where applicable
• Understanding the nature and purpose of the business relationship
• Conducting ongoing monitoring of transactions

3. Individual Client Requirements

For individual clients, we require the following documentation:

4. Corporate Client Requirements (KYB)

For corporate clients, we require:

5. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence in higher-risk situations, including:

• Politically Exposed Persons (PEPs) and their family members/close associates
• Clients from high-risk countries identified by FATF or HM Treasury
• Complex corporate structures
• Unusually large transactions
• Transactions with no apparent economic purpose

EDD may include additional documentation requirements, senior management approval, more frequent reviews, and enhanced transaction monitoring.

6. Politically Exposed Persons (PEPs)

A PEP is an individual who holds, or has held within the past 12 months, a prominent public function. This includes:

• Heads of state, heads of government, ministers, and deputy ministers
• Members of parliament or similar legislative bodies
• Members of governing bodies of political parties
• Members of supreme courts or constitutional courts
• Senior executives of state-owned enterprises
• High-ranking military officials
• Senior officials of international organisations

Family members and known close associates of PEPs are also subject to EDD requirements.

7. Sanctions Screening

We screen all clients against relevant sanctions lists, including:

• HM Treasury Consolidated List
• EU Consolidated List
• UN Security Council Sanctions List
• OFAC Specially Designated Nationals List

We will not establish business relationships with, or conduct transactions for, sanctioned individuals or entities.

8. Ongoing Monitoring

We conduct ongoing monitoring of our client relationships, including:

• Transaction monitoring to identify unusual or suspicious activity
• Periodic review of client information and documentation
• Screening against updated sanctions lists
• Risk assessment reviews

9. Record Keeping

In accordance with UK AML regulations, we retain copies of:

• Identity verification documents for at least 5 years after the end of the business relationship
• Transaction records for at least 5 years after the transaction
• All CDD and EDD documentation and findings

10. Refusal of Business

We reserve the right to refuse to establish or continue a business relationship if:

• Satisfactory identification cannot be obtained
• There is reason to suspect money laundering or terrorist financing
• The client appears on a sanctions list
• The client refuses to provide required information

11. Contact Us

If you have any questions about our KYC/KYB requirements or need assistance with the verification process, please contact our compliance team: