AML/CFT Policy

2. Our Legal Obligations

As a reporting entity under the AML/CFT Act, SBE is required to:

•Conduct risk assessments of our business and customers

•Implement and maintain an AML/CFT compliance programme

•Conduct customer due diligence (CDD) on all customers

•Monitor transactions for suspicious activity

•Report suspicious transactions to the New Zealand Police Financial Intelligence Unit

•Report prescribed transactions (cash transactions of NZD 10,000 or more, or equivalent)

•Maintain records of CDD information and transactions

•Appoint a compliance officer responsible for AML/CFT compliance

•Provide AML/CFT training to all relevant staff

•Conduct independent audits of our compliance programme

3. Customer Due Diligence (CDD)

We are required by law to verify the identity of all customers before conducting transactions. CDD must be completed before or, in certain circumstances, during the course of establishing a business relationship.

The level of CDD applied depends on the assessed risk of the customer and the nature of the transaction.

3.1 Standard CDD

For all customers, we require:

•Full legal name

•Date of birth

•Current residential address

•One form of valid government-issued photo identification:

—New Zealand passport

—New Zealand driver's licence

—Overseas passport

—New Zealand firearms licence

•One form of proof of current address (dated within 3 months):

—Utility bill (power, gas, water, internet)

—Bank or credit card statement

—Government correspondence (IRD, council rates)

—Tenancy agreement

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence may be required in the following circumstances:

•Transactions above certain value thresholds

•Customers assessed as higher risk based on our risk assessment

•Politically Exposed Persons (PEPs) — individuals who hold, or have held, a prominent public function in New Zealand or overseas, and their close associates and family members

•Complex or unusually large transactions

•Transactions with no apparent lawful purpose

•Customers from higher-risk jurisdictions

EDD may include additional identity verification, enhanced monitoring of transactions, and obtaining information about the source of funds or wealth.

3.3 Companies, Trusts & Other Entities

For customers that are not natural persons (individuals), we require additional information including:

•Companies: Certificate of incorporation, company register extract, identification of directors, shareholders holding 25% or more, and beneficial owners

•Trusts: Trust deed, identification of trustees, settlors, and beneficiaries (or classes of beneficiaries)

•Partnerships: Partnership agreement and identification of all partners

Beneficial owners must be identified and verified in all cases.

4. What to Bring When You Visit

When visiting our Bishopdale store for the first time, or when CDD has not yet been completed, please bring:

1. A valid photo ID (one of the types listed above)

2. Proof of your current residential address (dated within the last 3 months)

3. Information about the source of funds for your purchase

If you are acting on behalf of a company or trust, please also bring the relevant entity documentation.

For online or phone transactions, we may request certified copies of these documents or use electronic identity verification methods.

5. Ongoing Monitoring

SBE conducts ongoing monitoring of customer transactions and business relationships. This includes:

•Reviewing transactions to ensure they are consistent with our knowledge of the customer

•Keeping CDD information up to date

•Identifying transactions that are unusual or inconsistent with the customer's profile

•Escalating and investigating potentially suspicious activity

We may contact you from time to time to update your CDD information or to seek clarification about transactions.

6. Suspicious Transaction Reporting

SBE is legally required to file Suspicious Activity Reports (SARs) with the New Zealand Police Financial Intelligence Unit when we have reasonable grounds to suspect that a transaction or activity may be related to money laundering or terrorism financing.

Important: Under section 46 of the AML/CFT Act, it is an offence for us to disclose ("tip off") to any person that a SAR has been or will be made. We are therefore unable to inform you if a report has been filed in relation to your account or transactions.

7. Record Keeping

SBE maintains records of:

•All CDD information and identity verification documents

•Transaction records, including the nature and value of each transaction

•Suspicious activity reports and supporting documentation

•Staff training records

•Risk assessments and compliance programme documentation

Records are retained for a minimum of 5 years after the end of the business relationship or the date of the transaction, whichever is later, in accordance with the AML/CFT Act.

8. Sanctions Compliance

SBE screens all customers against relevant sanctions lists, including those maintained by the New Zealand government, the United Nations, and other applicable jurisdictions. We will not knowingly conduct transactions with sanctioned individuals, entities, or countries.

9. Global Precious Metals Code

Southern Bullion Exchange operates with reference to the Global Precious Metals Code, which sets standards for ethics, governance, compliance, and best practice in the precious metals market. We are committed to maintaining the highest standards of integrity and transparency in all our dealings.

10. Staff Training

All SBE staff involved in customer-facing roles or transaction processing receive regular AML/CFT training. Training covers the identification of suspicious activity, CDD procedures, reporting obligations, and the consequences of non-compliance. Training records are maintained and the programme is reviewed annually.

11. Contact & Questions

If you have any questions about our AML/CFT obligations or the CDD process:

AML/CFT Compliance Officer

Southern Bullion Exchange Limited

Shop 9 Bishopdale Court

Bishopdale 8053, Christchurch

New Zealand

Phone: 021 153 1763

Email: southernbullionnz@gmail.com

For more information about AML/CFT in New Zealand:

Department of Internal Affairs — www.dia.govt.nz

New Zealand Police Financial Intelligence Unit — www.police.govt.nz/advice/financial-intelligence-unit

© 2026 Southern Bullion Exchange Limited. All rights reserved.
This document does not constitute legal or financial advice.