Compliance & Anti-Money Laundering (AML) Policy
1. Introduction
West Pokot Gold Mining is committed to conducting its gold sourcing, trading, and export-related activities with integrity, transparency, and accountability. We seek to prevent our business from being used for money laundering, terrorist financing, fraud, corruption, or other unlawful activities.
2. Purpose
This policy outlines our approach to:
Customer and supplier identification.
Transaction verification and monitoring.
Gold provenance and responsible sourcing.
Record keeping and confidentiality.
Sanctions screening.
Identifying and escalating suspicious transactions.
Compliance with applicable Kenyan laws and regulations.
3. Scope
This policy applies to the Company’s directors, employees, representatives, contractors, and relevant business partners involved in gold sourcing, procurement, trading, bulk supply, payments, and export-related activities.
4. Legal Compliance
The Company seeks to comply with applicable Kenyan laws and regulations, including the Proceeds of Crime and Anti-Money Laundering Act, 2009, as amended, relevant regulations, and applicable mining, mineral dealing, and export requirements.
The Company will fulfil the registration, licensing, reporting, and record-keeping obligations applicable to its activities and legal status.
5. Customer Identification and Due Diligence
Before proceeding with a transaction, we may request information to verify the identity and legitimacy of customers and relevant business parties.
This may include:
Valid identification documents.
Company registration details.
Directors and beneficial ownership information.
Contact and business details.
The purpose and nature of the proposed transaction.
Source of funds and, where appropriate, source of wealth.
Additional information may be requested where necessary to address compliance concerns.
6. Supplier Verification and Gold Provenance
We recognise the importance of verifying the lawful origin and movement of gold.
Where applicable, supplier checks may include reviewing identification, relevant licences or permits, sourcing records, chain-of-custody documentation, purchase records, transport documents, and assay information.
We will not knowingly engage in transactions involving unlawfully sourced, stolen, smuggled, or criminally derived gold.
7. Transaction Verification
Transactions may be reviewed to confirm:
The identities of relevant parties.
Gold type, quantity, weight, and declared fineness.
Available assay and authenticity documentation.
The commercial purpose of the transaction.
Payment arrangements and source of funds, where appropriate.
Relevant licences, permits, and export documentation.
We may request clarification, suspend processing, or decline a transaction where information is incomplete, inconsistent, or cannot be satisfactorily verified.
8. Risk Assessment and Enhanced Due Diligence
We apply a risk-based approach to customers, suppliers, transactions, and jurisdictions.
Additional checks may be required where there are concerns involving unclear ownership, unusual transaction patterns, unexplained payments, uncertain gold provenance, sanctions exposure, or higher-risk jurisdictions.
Enhanced checks may include additional documentation, further verification, management review, or refusal to proceed.
9. Sanctions Screening
Where appropriate and required, we screen relevant customers, suppliers, beneficial owners, and transaction parties against applicable sanctions and restricted-party information.
Potential matches are reviewed before proceeding. Transactions may be paused or declined where applicable legal restrictions prohibit them.
10. Payment Controls
We seek to ensure that payments are transparent, appropriately documented, and consistent with the verified transaction.
Unexplained third-party payments, unusual overpayments, changes to payment instructions, or requests to conceal payment origins may be subject to further review.
We may delay or decline transactions where payment arrangements raise unresolved compliance concerns.
11. Suspicious Transaction Controls
We remain alert to potentially suspicious activity, including:
Attempts to conceal the identity of a buyer or seller.
Unexplained changes in payment arrangements.
Transactions without a clear commercial purpose.
Inconsistencies in gold quantity, value, or assay information.
Gaps in sourcing or ownership documentation.
Attempts to bypass verification or legal requirements.
These indicators do not automatically establish wrongdoing but may require further assessment.
12. Reporting and Escalation
Employees and representatives should promptly escalate compliance concerns to authorised management or the designated compliance contact.
Where legally required, the Company will report suspicious transactions or activities to the relevant authorities, including the Financial Reporting Centre (FRC), in accordance with applicable law.
We will protect the confidentiality of internal reviews and regulatory reports and will not unlawfully disclose information about a report or investigation.
13. Record Keeping
We seek to maintain accurate records relating to customer verification, supplier checks, gold provenance, transactions, payments, and compliance reviews.
Records may include identification documents, beneficial ownership information, contracts, invoices, payment records, assay reports, sourcing documents, licences, permits, and relevant compliance assessments.
Records will be retained for the periods required by applicable law and handled securely.
14. Confidentiality and Data Protection
Personal and business information collected for compliance purposes will be handled with appropriate safeguards and in accordance with applicable data protection requirements and our Privacy Policy.
Information will be shared only where necessary for legitimate business purposes, legal obligations, regulatory reporting, or other lawful grounds.
15. Employee Responsibilities
Relevant personnel are expected to understand and follow this policy and applicable compliance procedures.
The Company may provide guidance or training on customer verification, financial crime risks, gold provenance, record keeping, and the escalation of suspicious activity.
Employees are encouraged to raise concerns in good faith.
16. Non-Compliance
Failure to comply with this policy may result in internal disciplinary action, suspension or termination of a business relationship, refusal of a transaction, or referral to relevant authorities where required.
We reserve the right to request additional information or decline business where compliance concerns remain unresolved.
17. Policy Review
This policy will be reviewed periodically and when necessary to reflect changes in our operations, risk exposure, applicable legislation, or regulatory guidance.
Updates will be published on this page where appropriate.
18. Contact Information
West Pokot Gold Mining
Email: gold@westpokot.gold
Telephone: +254 720 261 802
Address: West Pokot, Kenya
Website: www.westpokot.gold
West Pokot Gold Mining is committed to conducting its gold sourcing, trading, and export-related activities with integrity, transparency, and accountability. We seek to prevent our business from being used for money laundering, terrorist financing, fraud, corruption, or other unlawful activities.
2. Purpose
This policy outlines our approach to:
Customer and supplier identification.
Transaction verification and monitoring.
Gold provenance and responsible sourcing.
Record keeping and confidentiality.
Sanctions screening.
Identifying and escalating suspicious transactions.
Compliance with applicable Kenyan laws and regulations.
3. Scope
This policy applies to the Company’s directors, employees, representatives, contractors, and relevant business partners involved in gold sourcing, procurement, trading, bulk supply, payments, and export-related activities.
4. Legal Compliance
The Company seeks to comply with applicable Kenyan laws and regulations, including the Proceeds of Crime and Anti-Money Laundering Act, 2009, as amended, relevant regulations, and applicable mining, mineral dealing, and export requirements.
The Company will fulfil the registration, licensing, reporting, and record-keeping obligations applicable to its activities and legal status.
5. Customer Identification and Due Diligence
Before proceeding with a transaction, we may request information to verify the identity and legitimacy of customers and relevant business parties.
This may include:
Valid identification documents.
Company registration details.
Directors and beneficial ownership information.
Contact and business details.
The purpose and nature of the proposed transaction.
Source of funds and, where appropriate, source of wealth.
Additional information may be requested where necessary to address compliance concerns.
6. Supplier Verification and Gold Provenance
We recognise the importance of verifying the lawful origin and movement of gold.
Where applicable, supplier checks may include reviewing identification, relevant licences or permits, sourcing records, chain-of-custody documentation, purchase records, transport documents, and assay information.
We will not knowingly engage in transactions involving unlawfully sourced, stolen, smuggled, or criminally derived gold.
7. Transaction Verification
Transactions may be reviewed to confirm:
The identities of relevant parties.
Gold type, quantity, weight, and declared fineness.
Available assay and authenticity documentation.
The commercial purpose of the transaction.
Payment arrangements and source of funds, where appropriate.
Relevant licences, permits, and export documentation.
We may request clarification, suspend processing, or decline a transaction where information is incomplete, inconsistent, or cannot be satisfactorily verified.
8. Risk Assessment and Enhanced Due Diligence
We apply a risk-based approach to customers, suppliers, transactions, and jurisdictions.
Additional checks may be required where there are concerns involving unclear ownership, unusual transaction patterns, unexplained payments, uncertain gold provenance, sanctions exposure, or higher-risk jurisdictions.
Enhanced checks may include additional documentation, further verification, management review, or refusal to proceed.
9. Sanctions Screening
Where appropriate and required, we screen relevant customers, suppliers, beneficial owners, and transaction parties against applicable sanctions and restricted-party information.
Potential matches are reviewed before proceeding. Transactions may be paused or declined where applicable legal restrictions prohibit them.
10. Payment Controls
We seek to ensure that payments are transparent, appropriately documented, and consistent with the verified transaction.
Unexplained third-party payments, unusual overpayments, changes to payment instructions, or requests to conceal payment origins may be subject to further review.
We may delay or decline transactions where payment arrangements raise unresolved compliance concerns.
11. Suspicious Transaction Controls
We remain alert to potentially suspicious activity, including:
Attempts to conceal the identity of a buyer or seller.
Unexplained changes in payment arrangements.
Transactions without a clear commercial purpose.
Inconsistencies in gold quantity, value, or assay information.
Gaps in sourcing or ownership documentation.
Attempts to bypass verification or legal requirements.
These indicators do not automatically establish wrongdoing but may require further assessment.
12. Reporting and Escalation
Employees and representatives should promptly escalate compliance concerns to authorised management or the designated compliance contact.
Where legally required, the Company will report suspicious transactions or activities to the relevant authorities, including the Financial Reporting Centre (FRC), in accordance with applicable law.
We will protect the confidentiality of internal reviews and regulatory reports and will not unlawfully disclose information about a report or investigation.
13. Record Keeping
We seek to maintain accurate records relating to customer verification, supplier checks, gold provenance, transactions, payments, and compliance reviews.
Records may include identification documents, beneficial ownership information, contracts, invoices, payment records, assay reports, sourcing documents, licences, permits, and relevant compliance assessments.
Records will be retained for the periods required by applicable law and handled securely.
14. Confidentiality and Data Protection
Personal and business information collected for compliance purposes will be handled with appropriate safeguards and in accordance with applicable data protection requirements and our Privacy Policy.
Information will be shared only where necessary for legitimate business purposes, legal obligations, regulatory reporting, or other lawful grounds.
15. Employee Responsibilities
Relevant personnel are expected to understand and follow this policy and applicable compliance procedures.
The Company may provide guidance or training on customer verification, financial crime risks, gold provenance, record keeping, and the escalation of suspicious activity.
Employees are encouraged to raise concerns in good faith.
16. Non-Compliance
Failure to comply with this policy may result in internal disciplinary action, suspension or termination of a business relationship, refusal of a transaction, or referral to relevant authorities where required.
We reserve the right to request additional information or decline business where compliance concerns remain unresolved.
17. Policy Review
This policy will be reviewed periodically and when necessary to reflect changes in our operations, risk exposure, applicable legislation, or regulatory guidance.
Updates will be published on this page where appropriate.
18. Contact Information
West Pokot Gold Mining
Email: gold@westpokot.gold
Telephone: +254 720 261 802
Address: West Pokot, Kenya
Website: www.westpokot.gold
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West Pokot Gold Mining is a registered Kenyan gold enterprise focused on responsible gold sourcing, mining, and trade globally. We connect verified African gold with international buyers, with product purity, licensing, and export documentation subject to applicable verification and regulatory requirements.