Last Updated: August 26, 2026
1. Policy Statement
Lumia Gold and Minerals Ltd is committed to conducting legitimate precious-metals business with identifiable and credible counterparties.
Our policy is to take reasonable and proportionate steps to prevent our business and services from being used for:
- Money laundering
- Terrorism financing
- Proliferation financing
- Fraud
- Corruption
- Bribery
- Sanctions evasion
- Illegal mineral trading
- Other financial crime
Kenya’s Financial Reporting Centre identifies dealers in precious metals as Designated Non-Financial Businesses and Professions within the AML/CFT framework. The FRC’s due-diligence guidance identifies customer due diligence, enhanced due diligence, politically exposed persons, beneficial ownership and ongoing due diligence among relevant requirements.
2. Purpose
This policy establishes Lumia’s general approach to:
- Client identification
- Corporate verification
- Beneficial ownership
- Buyer due diligence
- Supplier due diligence
- Transaction monitoring
- Source of funds
- Source of gold
- Sanctions
- PEPs
- Enhanced due diligence
- Record keeping
- Suspicious activity
3. Scope
This policy can apply to:
- Gold buyers
- Gold sellers
- Mining companies
- Dealers
- Exporters
- Investors
- Refineries
- Representatives
- Agents
- Commercial partners
4. Risk-Based Approach
Not every transaction carries the same risk.
Our level of due diligence can vary according to factors such as:
- Country
- Product
- Transaction size
- Counterparty
- Ownership structure
- Payment method
- Gold origin
- Supply-chain complexity
- Sanctions exposure
- Responsible-sourcing risk
Higher-risk transactions may require Enhanced Due Diligence.
5. Customer Identification
Before establishing certain commercial relationships, we may request:
Individuals
- Full legal name
- Identification
- Nationality
- Residential or business address
- Contact information
- Role in transaction
Companies
- Legal company name
- Registration number
- Registered address
- Certificate of incorporation
- Directors
- Shareholders
- Beneficial owners
- Authorized representatives
- Nature of business
- Website
- Relevant licences
6. Beneficial Ownership
We may seek to determine who ultimately owns or controls a counterparty.
Where appropriate, we may request:
- Shareholding structure
- Director details
- Ultimate beneficial owner information
- Ownership declaration
Opaque ownership structures can trigger enhanced review.
7. Authorized Representatives
A person claiming to represent a company may be asked to establish authority.
This can involve:
- Corporate email
- Appointment letter
- Board authority
- Power of attorney
- Direct confirmation by principal
The title “broker,” “mandate,” or “representative” alone does not establish authority.
8. Buyer KYC
Qualified buyers may be asked to provide:
- Company information
- Authorized representative
- Beneficial ownership
- Product requirement
- Destination
- Refinery information where relevant
- Payment-party information
Large purchasing claims can require additional commercial verification.
9. Seller/Supplier KYC
Suppliers may be asked for:
- Corporate documents
- Mineral-related authorization
- Product origin
- Gold ownership
- Assay
- Quantity
- Supply capacity
- Export capability
- Beneficial ownership
- Bank beneficiary details
10. Source of Funds
Where appropriate, Lumia may seek information concerning how a buyer intends to fund a transaction.
This can include understanding:
- Funding entity
- Bank account
- Relationship between payer and buyer
- Commercial source of funds
Unexplained third-party payments can trigger enhanced review or rejection.
11. Source of Wealth
Where required by risk assessment, additional information may be requested concerning a counterparty’s broader source of wealth.
This can be especially relevant in enhanced-due-diligence situations.
12. Source of Gold
For precious-metals transactions, knowing the source of the commodity is particularly important.
Information may include:
- Country of origin
- Mine
- Producer
- Cooperative
- Dealer
- Previous owner
- Cross-border movements
- Exporter
The country from which gold is exported should not automatically be assumed to be its original mining source.
13. Legal Ownership
We may seek evidence or reasonable confirmation that the proposed seller has the legal right to sell the product.
Physical possession alone is not always sufficient evidence of ownership.
14. Product Verification
Depending on transaction risk, product verification may include:
- Physical inspection
- Weight verification
- Bar count
- Assay
- Inventory records
- Supplier confirmation
15. Politically Exposed Persons
A Politically Exposed Person, or PEP, may require enhanced review because of the position held and associated risk.
PEP status does not itself imply wrongdoing.
Additional steps may include:
- Source-of-funds review
- Source-of-wealth review
- Beneficial-ownership verification
- Senior approval where required
The FRC’s current DNFBP due-diligence guidance expressly includes PEP considerations.
16. Sanctions Screening
Where appropriate, parties may be screened against applicable sanctions and watchlists.
Relevant persons can include:
- Company
- Directors
- Beneficial owners
- Authorized representatives
- Payment beneficiaries
Potential sanctions matches require further review.
17. Enhanced Due Diligence
EDD may be required where circumstances indicate increased risk.
Examples can include:
- Complex ownership
- High-value transactions
- Unclear mineral origin
- Conflict-affected supply chains
- Unusual payment structures
- Unrelated third-party payments
- PEP involvement
- Sanctions concerns
- Cross-border complexity
- Inconsistent documentation
EDD can involve requesting additional documents, independent verification and management approval.
18. Ongoing Due Diligence
Due diligence does not necessarily end after onboarding.
We may continue to review:
- Transaction behavior
- Payment changes
- New counterparties
- Beneficial ownership
- Supply source
- Gold origin
- Documentation
The FRC’s guidance identifies ongoing due diligence as part of the relevant framework.
19. Transaction Monitoring
Transactions can be reviewed for unusual patterns such as:
- Unexpected beneficiary changes
- Unrelated third-party payments
- Unexplained large transactions
- Unusual geographic routing
- Repeated last-minute transaction changes
- Inconsistent product volumes
- Lack of reasonable economic purpose
FRC guidance states that reporting institutions should monitor complex, unusual or suspicious transactions and unusual transaction patterns.
20. Suspicious Transactions
Where Lumia is subject to applicable reporting obligations and develops legally reportable suspicion, information may be provided to the competent authority as required by law.
Kenya’s FRC states that reporting institutions have suspicious transaction/activity reporting duties under POCAMLA.
We will not disclose confidential reporting activity where disclosure is prohibited.
21. Prohibited Relationships
Lumia may decline relationships involving reasonable concerns regarding:
- Anonymous counterparties
- Fictitious companies
- Fraudulent documents
- Illegal mineral origin
- Sanctions violations
- Money laundering
- Terrorism financing
- Bribery or corruption
- Unexplained payment beneficiaries
- Deliberate concealment of beneficial ownership
- Refusal to provide essential KYC information
22. Cash Transactions
High-value cash arrangements may present significant AML and security risk.
Lumia may decline transaction structures that do not provide an appropriate transparent financial trail or satisfy applicable compliance requirements.
23. Third-Party Payments
Payments by or to parties outside the contract require explanation and, where appropriate, additional verification.
We may reject a payment structure where the relationship among:
Buyer → Payer → Seller → Beneficiary
cannot be satisfactorily established.
24. Cryptocurrency and Virtual Assets
Where a proposed transaction involves virtual assets, additional risk assessment may be required before acceptance.
Lumia reserves the right to decline payment methods that cannot satisfy relevant legal, compliance, banking or transaction requirements.
25. Gold From Higher-Risk Regions
Gold originating from conflict-affected or otherwise higher-risk supply chains can require enhanced due diligence.
Relevant issues can include:
- Mine of origin
- Chain of custody
- Armed-group risk
- Smuggling
- Serious human-rights concerns
- Cross-border movement
- Sanctions
26. Responsible Sourcing
Our AML/KYC framework works alongside responsible-sourcing considerations.
A transaction can involve genuine gold yet still create unacceptable legal or supply-chain risk.
27. Record Keeping
Where required, Lumia may retain appropriate records concerning:
- KYC
- Beneficial ownership
- Transactions
- Contracts
- Payments
- Due diligence
- Communications
- Compliance decisions
Retention will be undertaken consistently with applicable AML and data-protection requirements.
28. Data Protection
KYC information is sensitive commercial and personal information.
Lumia seeks to collect only information reasonably required and protect it in accordance with applicable data-protection principles.
The ODPC states that Kenyan data subjects have rights including being informed, access, objection, correction and deletion in relevant circumstances.
29. Confidentiality
KYC and compliance records are not ordinarily disclosed publicly.
They may be shared where necessary with:
- Regulators
- Law-enforcement authorities
- Banks
- Lawyers
- Compliance advisers
- Transaction counterparties
- Other appropriate parties
subject to law and legitimate commercial requirements.
30. FRC Registration and Reporting
The Financial Reporting Centre states that reporting institutions are required to register with the Centre through its goAML system, and its compliance page describes dealers in precious metals as reporting institutions within the relevant framework.
Important for Lumia: this paragraph should only say that “Lumia is registered with the FRC” if Lumia has actually completed registration and received its organization number. Until then, do not publish such a claim.
31. Compliance Governance
Where required by applicable law and the size and nature of operations, Lumia should maintain appropriate internal controls concerning:
- AML/CFT/CPF risk
- KYC
- Record keeping
- Employee awareness
- Reporting
- Compliance oversight
32. Policy Review
This AML/KYC Policy may be reviewed periodically to reflect:
- Legal developments
- FRC guidance
- Regulatory changes
- Business changes
- Risk-assessment findings
33. No Tipping Off
Where a transaction is under regulatory or suspicious-activity review, Lumia will comply with applicable confidentiality and non-disclosure requirements.
34. Cooperation With Authorities
Where legally required, Lumia may cooperate with competent Kenyan or international authorities regarding:
- Financial crime
- Fraud
- Money laundering
- Terrorism financing
- Sanctions
- Illegal mineral trade
35. Customer Responsibility
Customers and counterparties are expected to:
- Provide accurate information
- Provide genuine documents
- Disclose relevant ownership
- Explain transaction purpose
- Use legitimate funds
- Avoid unlawful mineral sources
- Notify Lumia of material changes
Submitting false KYC documentation can result in termination of the commercial relationship and other action where appropriate.
36. Right to Terminate
Lumia reserves the right to suspend or terminate a commercial relationship where:
- KYC is incomplete
- Information is false
- Compliance concerns arise
- Transaction risk becomes unacceptable
- Applicable law requires termination
37. Compliance Contact
For AML/KYC and compliance inquiries:
Lumia Gold and Minerals Ltd
Nairobi, Kenya
Email: info@lumiagoldminerals.com