KEPM has voluntarily established a risk-based AML Program. It is the Policy of the Company to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by voluntarily complying with applicable requirements under the Bank Secrecy Act, as amended by the USA PATRIOT Act and all related implementing regulations.
The AML Program will be reasonably designed to prevent the Company from being used to facilitate money laundering and the financing of terrorist activity through the purchase of precious metals. The AML Policy will be reviewed and updated by the designated AML Compliance Officer on a regular basis, at a minimum annually, to ensure appropriate procedures and internal controls are in place to account for both changes in regulations and changes in the Company’s business. To accomplish this, the Company will conduct an annual AML risk assessment. The results of the risk assessment will drive improvements in the Company’s AML risk management by identifying money laundering risks, assessing how these risks are controlled and mitigated, determining the remaining residual risk, and identifying possible enhancements to existing controls, including policies, procedures, and processes.
An independent third-party will conduct a review of the Company’s AML Program and Policy on a regular periodic basis, either annually or no later than every 18 months. Such testing shall reflect a scope and frequency commensurate with the risk assessment conducted by the AML Compliance Officer.
To ensure independence, the independent third party will not assume any operational duties related to the AML Policy. The independent third party will maintain a record of the independent review and testing. The independent testing is intended to confirm that the AML Program operates properly.
ONGOING EMPLOYEE AML TRAINING
Training will cover money laundering and facilitation risks for illicit activity, to include current and emerging risk factors. Training will also address the legal and regulatory framework, as well as the Company’s policies and procedures, and employee roles and responsibilities regarding AML compliance. Training will be conducted on at least an annual basis and will be more targeted for certain employees as appropriate. KEPM will document all training, to include dates of training, employees trained and training content.