1. Purpose

This Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy outlines the procedures and controls adopted by Gold Australia (SA) Pty Ltd ("the Company") to comply with its obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), relevant AUSTRAC rules, and guidance notes.

The purpose of this policy is to prevent the Company from being used to facilitate money laundering, terrorism financing, or other financial crimes.

2. Scope

This policy applies to all clients of the Company and covers:

• Customer identification and verification (Know Your Customer – KYC);
• Monitoring of transactions;
• Reporting of suspicious matters and threshold transactions;
• Recordkeeping.

3. Customer Identification and Verification (KYC)

3.1 Verification Requirements
The Company verifies the identity of all customers involved in:

• Transactions of AUD $5,000 or more;
• Cash transactions of AUD $10,000 or more (Threshold Transaction Reports);
• Any activity deemed suspicious, regardless of value.

3.2 Verification Methods
Customer identification may be collected through:

• In-person presentation of government-issued ID;
• Submission of scanned ID via email or secure upload;
• Use of approved third-party digital ID verification systems.

3.3 Business and Trust Clients
Where the client is a company, trust, or SMSF, additional documents may be required:

• ASIC company extracts or ABN registration;
• Trust deeds and corporate documents;
• Identification of directors, trustees, and beneficiaries.

3.4 Order Processing
No order will be finalised, dispatched, or delivered until the customer's identity is verified in accordance with AUSTRAC obligations.

4. Transaction Monitoring and Reporting

4.1 Monitoring Activities
The Company monitors all transactions to identify:

• Unusual transaction patterns or behaviour;
• Structuring of transactions to avoid thresholds;
• Repeated purchases just below reporting limits.

4.2 Reporting Obligations
The Company is required to report the following to AUSTRAC:

• Threshold Transaction Reports (TTR): Cash transactions of AUD $10,000 or more;
• Suspicious Matter Reports (SMR): Any transaction that raises suspicion of money laundering, terrorism financing, or unlawful activity.

All reports are submitted securely through AUSTRAC’s online portal within required timeframes.

5. Recordkeeping

5.1 Data Retention
We maintain full and accurate records of:

• KYC documentation and customer identification;
• Transaction details and payment methods;
• Any reports lodged with AUSTRAC.

5.2 Duration and Security
Records are securely stored in encrypted digital systems for a minimum of seven (7) years in accordance with legal obligations. Access is restricted to authorised personnel only.

6. Policy Review

This policy is reviewed annually or whenever there are significant changes in legislation, AUSTRAC guidance, or the Company's operations.

7. Contact

For any enquiries related to this AML/CTF Policy, please contact:

Gold Australia (SA) Pty Ltd
Phone: 1300 295 833
Email: hello@asgoodasgold.com.au
Website: www.asgoodasgold.com.au
Office Locations: Level 1, 161 Ward Street, North Adelaide SA 5006