AML Policy
The Diamond District Anti-Money Laundering (AML) Policy
This Anti-Money Laundering Policy sets out The Diamond District's approach to ensuring full compliance with all applicable UK laws and regulations to prevent money laundering and to appropriately manage associated risks.
The primary risks within the trade of diamonds and jewellery include mis-declaration of imported items, such as importing more items than declared, incorrect valuation of items, or shipping fewer items than listed, as well as receipt of funds from illegitimate or unverified sources.
To mitigate these risks, The Diamond District has implemented robust policies and procedures to facilitate and support legitimate trade within the jewellery industry.
1. Company Policy
It is the policy of The Diamond District to actively prevent money laundering in the diamond and jewellery trade. Our AML policies and procedures are designed to ensure compliance with UK regulations and will be reviewed and updated regularly to remain consistent with regulatory requirements and business practices.
2. Pricing
We ensure that product prices are set fairly and not structured to facilitate money laundering, tax evasion, or illicit transfer pricing.
3. Quality Control
Our quality control procedures include verification of all microscopic laser inscriptions on diamonds against their respective GIA (Gemological Institute of America) or other recognised certificates, as well as invoices of sale, to ensure authenticity and legitimate origin.
4. AML Compliance Officer Designation and Duties
The Diamond District has appointed an Anti-Money Laundering Compliance Officer (AML Compliance Officer) responsible for overseeing the firm's AML programme. Duties include monitoring compliance with AML obligations, verifying the legitimacy of funds, and ensuring accurate valuation of all goods.
5. Know Your Customer (KYC) Programme
The KYC procedures apply to all customers and suppliers opening new accounts with The Diamond District.
A. Sign-up Process
During account registration, customers must complete a KYC form providing the required identification and business details.
B. Customers who refuse to provide information
If a potential or existing customer refuses to provide requested information, or supplies deliberately misleading data, we will not open a new account and may consider closing any existing accounts after evaluating associated risks.
C. Verifying Information
We verify information within a reasonable timeframe before or after account opening. Depending on the account type and transaction nature, we may decline to complete a transaction until verification is complete.
6. Monitoring Accounts for Suspicious Activity
We monitor accounts for suspicious transactions or activities relevant to our business. The AML Compliance Officer is responsible for reviewing flagged activity and determining any necessary further steps.
7. Responding to Red Flags and Suspicious Activity
When our monitoring systems or employees detect red flags or potentially suspicious activity, the AML Compliance Officer will review the matter. Actions may include gathering additional information from customers or suppliers, consulting internal or third-party sources, contacting relevant authorities, freezing accounts, or preventing transactions from proceeding.