AML Compliance Policy

Purpose & Scope

R & T Coin & Precious Metals, LLC is committed to full compliance with the USA PATRIOT Act,

the Bank Secrecy Act (BSA), and all applicable Anti-Money Laundering (AML) regulations. This policy outlines the procedures we follow to prevent money laundering, terrorist financing, and other financial crimes. This policy applies to all employees, contractors, and partners engaged in financial transactions within the company.

Customer Identification Program (CIP)

We implement a Customer Identification Program (CIP) for all transactions exceeding $10,000 or in cases where suspicious activity is suspected.

Requirements:

Government-issued photo identification (e.g., driver’s license, passport)
Proof of address (utility bill, lease agreement)
Taxpayer Identification Number (TIN) or Social Security Number (SSN) when applicable
Business verification documents for corporate transactions

If a customer refuses to provide the required identification, we reserve the right to deny the

transaction and report it to the appropriate authorities.

Transaction Monitoring & Reporting

We actively monitor, review, and assess financial transactions for suspicious activity, including but not limited to:

Large cash transactions
Structured deposits (transactions split to avoid reporting requirements)
Transactions involving high-risk countries
Rapid movement of funds between unrelated accounts

Suspicious Activity Reporting (SAR)

If a transaction appears suspicious, we will:

Document and investigate the transaction
File a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network(FinCEN) if necessary
Maintain records of the report for at least five (5) years4.

Record Keeping Requirements

We maintain the following transaction records for a minimum of five (5) years:

Copies of customer identification documents
Transaction logs for high-value trades
Internal reports regarding suspicious activities
Filed SARs and any related documentation

Employee Training & Responsibilities

All employees handling transactions are required to:

Complete annual AML training on recognizing and reporting suspicious activity
Stay informed about changes in AML laws and compliance obligations
Report any concerns to the company’s Compliance Officer

Richard Hannon

Compliance Officer | R & T Coin & Precious Metals, LLC

📧 Email: Info@randtcoinandpreciousmetals.com

📞 Phone: (203) 309-6643

🌐 Website: www.randtcoinandpreciousmetals.com

📍 Business Address: 314 Main Street #4593, Wallingford, CT 06492

Compliance & Enforcement

Failure to comply with this AML policy may result in:

Disciplinary action, including termination
Legal action and penalties under applicable laws
Criminal prosecution in cases of willful non-compliance

This policy will be reviewed and updated annually to ensure compliance with all federal and state regulations.

Contact Information

For questions or reporting suspicious activity, contact: