AML & Compliance

MM Precious Trading Ltd operates under a robust Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) framework designed for the precious metals and gemstones sector.

As a [licensed / pending-authorisation] Dealer in Precious Metals and Stones (DPMS) in Malta, our compliance model aligns with:

• FIAU Implementing Procedures – Part I
   
• FATF Risk-Based Approach for DPMS
   
• Maltese supervisory guidelines and industry standards
   

Our objective is clear:
to ensure that our operations in gemstones, gold and other high-value goods cannot be used for illicit financial activity.

MM Precious Trading operates under a B2B, low-volume / high-value model, involving:

• sourcing and trading gemstones, gold, precious metals and select high-value goods
   
• cross-border transactions and international sourcing
   
• distribution to EU-based and global institutional clients
   
• payments executed exclusively through regulated financial institutions
   
• secure, professional logistics for high-value shipments
   

We apply a Risk-Based Approach (RBA), adjusting AML controls to:

• the counterparty’s profile
   
• jurisdictions involved
   
• nature and value of goods
   
• transactional complexity

Our AML/CFT framework is supervised by

AML Our Compliance Officer

Responsibilities include:

• implementing and maintaining AML/CFT controls
   
• approving the Business Risk Assessment (BRA)
   
• supervising KYC / CDD on clients and suppliers
   
• reviewing unusual or complex transactions
   
• assessing whether an STR must be submitted to the FIAU
   
• serving as the primary contact point for supervisory authorities

Before establishing a business relationship or executing a significant transaction, MM Precious Trading performs Customer Due Diligence (CDD) on all relevant parties.

We verify:

• company registration details
   
• registered address and tax/VAT information
   
• identity of legal representatives
   
• business activities
   
• Ultimate Beneficial Owner (UBO), where applicable
   

Where higher risk factors exist, Enhanced Due Diligence (EDD) is applied, which may require:

• documentation on source of funds and source of goods
   
• deeper ownership verification
   
• analysis of the economic rationale
   

If required information cannot be obtained or verified, we do not enter into a business relationship.

Payments are accepted only through traceable banking channels or other regulated financial intermediaries.

In line with Maltese law, MM Precious Trading:

• does not accept or make cash payments of €10,000 or more, even if split into smaller amounts.
   

This policy is a fundamental element of our AML framework.

All business relationships are subject to ongoing monitoring.
We identify unusual elements such as:

• transactions inconsistent with the expected profile
   
• irregular patterns in frequency, value or geography
   
• attempts to limit documentation or bypass controls
   
• payments from unrelated third parties
   
• discrepancies in commercial or customs documentation
   

Cases presenting red flags are escalated to the AML Compliance Officer.
Where reasonable suspicion exists, an STR may be filed with the FIAU in accordance with Maltese law.

We maintain comprehensive records for a minimum of five years, including:

• KYC / EDD files
   
• contracts and invoices
   
• customs and shipping documents
   
• transaction registers
   
• internal compliance assessments
   

This ensures full traceability and supports supervisory reviews.
 

Our AML framework evolves continuously through:

• annual AML/CFT training with a focus on DPMS risks
   
• updates to the AML Policy, BRA and procedures
   
• monitoring of FIAU, MFSA and FATF guidance
   
• adapting controls when entering new markets or product lines
   

By combining sector expertise with rigorous AML/CFT controls, MM Precious Trading aims to be a trusted partner for institutional clients, regulated intermediaries and professional buyers.

Each transaction must be:

• traceable
   
• supported by a clear economic purpose
   
• fully documented and compliant
   

This approach protects our clients, our partners and the integrity of the markets in which we operate.