Know Your Customer (KYC) & Anti-Money Laundering (AML) Policy

1. Introduction

Zeja Orivis BV, trading through Gold2Home.eu (“Gold2Home”, “we”, “us” or “our”), is committed to conducting its business in a lawful, transparent and responsible manner and to preventing its products and services from being used for money laundering, terrorist financing, fraud, sanctions evasion or other unlawful activities.

As a Belgian company engaged in the sale and purchase of precious metals, including investment gold and silver, we apply appropriate Know Your Customer (“KYC”) and Anti-Money Laundering and Counter-Terrorist Financing (“AML/CFT”) measures having regard to applicable Belgian and European Union legislation and the risks associated with transactions in precious metals.

This policy explains the measures that Gold2Home may apply when customers purchase products from us or sell precious metals to us.

2. Legal Framework

Our KYC and AML/CFT procedures take into account applicable Belgian and European legislation, including, where relevant:

• the Belgian Act of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash, as amended;
• applicable Belgian rules concerning payments and transactions involving precious metals;
• applicable European Union sanctions and restrictive measures;
• Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, to the extent applicable;
• applicable data protection legislation, including Regulation (EU) 2016/679 (GDPR).

Gold2Home may amend its procedures when required by changes in applicable legislation, regulatory guidance or the risk associated with a particular transaction or customer.

3. Customer Identification and Verification

Gold2Home may require a customer to complete an identity verification procedure before accepting, processing, dispatching or completing an order or a precious-metal buyback transaction.

Depending on the circumstances and the level of risk, we may request information or documents including:

• full legal name;
• date and place of birth;
• residential address;
• nationality;
• telephone number and email address;
• a valid passport, national identity card or other acceptable government-issued identification document;
• proof of residential address;
• bank account or payment information;
• information concerning the purpose and nature of the transaction;
• information or evidence concerning the source of funds and/or source of wealth where appropriate;
• additional information reasonably necessary to verify the customer's identity or assess the transaction.

For legal entities, companies or other organisations, we may additionally request information concerning:

• company name, registered office and registration number;
• directors or authorised representatives;
• ownership and control structure;
• ultimate beneficial owner(s) (UBOs);
• authority of the person acting on behalf of the organisation;
• nature and purpose of the business relationship or transaction.

We may verify information using reliable and independent documents, databases, registers or verification service providers.

4. When Enhanced Verification May Be Required

Gold2Home applies a risk-based approach. Additional information or enhanced verification may therefore be required where a transaction or customer presents an increased money-laundering, terrorist-financing, fraud or sanctions risk.

This may include, in particular:

• unusually large or complex transactions;
• multiple transactions that appear to be connected;
• transactions that are inconsistent with the information available about the customer;
• transactions involving high-risk jurisdictions;
• transactions involving politically exposed persons (PEPs), their family members or known close associates, where applicable;
• circumstances raising concerns regarding the origin of funds or assets;
• unusual payment arrangements or payments involving third parties;
• transactions where the purchaser, payer, recipient or account holder do not correspond;
• attempted structuring of transactions to avoid identification, verification or other compliance controls;
• circumstances giving rise to sanctions or other compliance concerns.

Gold2Home may request additional supporting documentation before proceeding with such a transaction.

5. Politically Exposed Persons (PEPs) and Sanctions Screening

Where appropriate and permitted or required by applicable law, Gold2Home may screen customers, beneficial owners and other relevant persons against:

• applicable EU and other legally relevant sanctions lists;
• politically exposed person (PEP) databases;
• other relevant compliance databases and publicly available information.

The fact that a person is a PEP does not automatically prevent that person from becoming a customer. It may, however, result in enhanced due diligence and requests for additional information.

Gold2Home will not knowingly carry out a transaction that would violate applicable sanctions or other mandatory restrictive measures.

6. Payments

Gold2Home does not accept cash payments.

Payments for purchases from Gold2Home must be made using one of the non-cash payment methods accepted by us, such as bank transfer or another electronic payment method made available through our website.

Gold2Home may require that payment is made from a bank account or payment instrument held in the name of the customer placing the order. Where the payer, customer, recipient or account holder are different persons, we may request additional information or documentation before processing the transaction.

We reserve the right to reject payments made by third parties or through payment arrangements that prevent us from reasonably identifying the origin of the funds.

For precious metals purchased by Gold2Home from customers, payment will be made exclusively using a traceable non-cash payment method and in accordance with applicable Belgian requirements and our internal procedures.

Transactions must not be artificially divided, structured or otherwise arranged for the purpose of avoiding applicable legal requirements or Gold2Home's KYC, AML/CFT or fraud-prevention controls.

7. Source of Funds and Source of Wealth

Where justified by the nature, value or risk of a transaction, Gold2Home may request information or documentary evidence concerning the origin of the funds used for a purchase or the origin of the customer's wealth.

Supporting documentation may include, depending on the circumstances:

• bank statements;
• evidence of employment or income;
• business income documentation;
• sale agreements;
• inheritance documentation;
• investment records;
• tax-related documentation;
• other appropriate evidence demonstrating the legitimate origin of funds or wealth.

For precious metals offered for sale to Gold2Home, we may also request evidence concerning their ownership, acquisition or provenance.

8. Refusal, Suspension or Cancellation of Transactions

Gold2Home reserves the right, subject to applicable law, to refuse, suspend or cancel a transaction or business relationship where:

• required identification or verification cannot be satisfactorily completed;
• requested information or documents are not provided;
• the information provided appears incorrect, inconsistent or misleading;
• there are reasonable concerns regarding the source of funds or assets;
• the transaction raises money-laundering, terrorist-financing, fraud or sanctions concerns;
• the transaction would breach applicable legislation or restrictive measures;
• the customer attempts to circumvent applicable KYC, AML/CFT or fraud-prevention controls.

Where permitted by law, funds received in connection with a transaction that cannot be completed will be returned through an appropriate traceable payment method.

Gold2Home may require any refund to be made to the original payer and/or to the bank account or payment instrument from which the original payment was received.

9. Suspicious Activity and Cooperation with Authorities

Gold2Home cooperates with competent Belgian and European authorities where required by applicable law.

Where applicable legal requirements require or permit a report, disclosure, freezing measure or other action in relation to a transaction or customer, Gold2Home may take the necessary action without prior notice to the customer where such notice is prohibited by law.

Gold2Home will not disclose information where doing so would constitute unlawful disclosure, including prohibited tipping-off, or would otherwise interfere with an investigation or legal obligation.

10. Record Keeping and Protection of Personal Data

Information and documents collected for KYC, AML/CFT, fraud-prevention or sanctions-compliance purposes are processed in accordance with applicable data protection legislation, including Regulation (EU) 2016/679 (GDPR).

Such information may be processed for purposes including:

• compliance with applicable legal obligations;
• customer and transaction verification;
• prevention and detection of money laundering, terrorist financing and fraud;
• sanctions compliance;
• protection of Gold2Home and its customers;
• establishment, exercise or defence of legal claims, where applicable.

Information will be retained only for the period required or permitted by applicable legislation and Gold2Home's legitimate record-keeping requirements.

Further information about the processing of personal data and the exercise of data protection rights is available in our Privacy Policy.

11. Customer Responsibility

Customers must provide accurate, complete and up-to-date information when requested.

By using Gold2Home's services, customers acknowledge that Gold2Home may request additional information or documentation where reasonably necessary for identity verification, fraud prevention, sanctions compliance or AML/CFT purposes.

Failure to provide requested information may result in an order or transaction being delayed, suspended, refused or cancelled.

12. Cross-Border Transactions

Gold2Home serves customers in multiple European Union Member States.

In addition to Belgian and directly applicable European Union requirements, certain transactions may be subject to mandatory rules or restrictions applicable in the customer's country, the country of delivery or another jurisdiction connected with the transaction.

Where necessary, Gold2Home may apply additional verification, payment or transaction requirements in order to comply with applicable legislation or appropriately manage legal, AML/CFT, sanctions and fraud risks.

13. Changes to This Policy

Gold2Home may update this KYC & AML Policy from time to time to reflect changes in legislation, regulatory requirements, guidance, business practices or risk assessments.

The version published on Gold2Home.eu at the time of the relevant transaction will apply, subject to mandatory provisions of applicable law.

14. Contact

Zeja Orivis BV
Reyndersstraat 30
2000 Antwerp
Belgium

Email: gold2home@gold2home.eu

For questions concerning our KYC and AML procedures, please contact us using the details above.