MyGold SpA AML POLICY — KYC — KYB Anti-Money Laundering — Customer Verification — Countering the Financing of Terrorism pursuant to Legislative Decree 231/2007 · Law 7/2000 · Bank of Italy Regulations for Public Offers | Version: OPO License: Bank of Italy No. 5008800 Contact: administration@mygold.world |
Identity verification is a legal requirement and a protection tool for all our customers. |
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Law 7/2000 Authorized OPO Bank of Italy No. 5008800 | D. Lgs. 231/2007 Anti-money laundering Italian AML legislation | KYC / KYB Verify Natural and legal persons | Risk-Based Approach Proportional to risk |
1. | WHY THIS POLICY |
MyGold SpA (hereinafter ” MyGold ” or “the Company”) is committed to fighting money laundering (AML ) and the financing of terrorism (CFT ) . This is a fundamental commitment, not just a regulatory obligation.
We believe that a healthy and transparent precious metals market requires responsible operators who adopt high standards of customer due diligence. This Policy transparently describes our approach to preventing financial crime, the procedures we use to verify customer identity, and the criteria we use to assess the risk associated with each business relationship.
Our commitment: MyGold guarantees that its physical gold trading and custody activities, including through qualified custodians, are conducted in full compliance with current legislation and are not used for illicit purposes, protecting our customers and the integrity of the gold market. |
2. | REGULATORY REFERENCES |
This Policy is drafted in accordance with the following regulatory framework:
Regulations | Description |
Law 17 January 2000, n. 7 | Gold trading regulations — establishment of the OPO register at the Bank of Italy; identification and registration requirements for gold transactions |
EU Regulation 2024/1624 (AMLR) | New European regulatory framework on anti-money laundering, which will introduce harmonized rules at EU level, with progressive application starting from 2027 |
Legislative Decree 21 November 2007, n. 231 (AML) | Italian anti-money laundering legislation — customer due diligence, data retention, SOS reporting to the UIF |
GDPR — EU Regulation 2016/679 | Personal data protection — legal basis for processing KYC/KYB data |
Bank of Italy Provisions for Public Offers | Supervisory provisions and operating instructions for Professional Gold Operators authorised under Law 7/2000 |
UIF Communications | Anomaly indicators for suspicious transactions in the precious metals and investment gold sector |
FATF / FATF Standards (2021+2024) | International recommendations on risk- based approach for precious metals operators — methodological reference |
3. | GLOSSARY |
Below are the main definitions and acronyms used in this Policy:
Acronym | Term | Definition |
AML | Anti-Money Laundering | Anti-money laundering: a set of measures to prevent and combat money laundering from illicit activities. |
CFT | Combating the Financing of Terrorism | Combating the Financing of Terrorism |
ML/TF | Money Laundering / Terrorist Financing | Money laundering and terrorist financing: the two main risks that AML/CFT procedures aim to prevent |
KYC | Know Your Customer | Verification of the identity of the individual customer: collection and verification of identification data, documentary evidence and the source of funds |
KYB | Know Your Business | In-depth verification of legal entity clients: collection and verification of corporate, director, and beneficial owner data. |
CDD | Customer Due Diligence | Customer due diligence: standard procedure applied to all customers |
EDD | Enhanced Due Diligence | Enhanced Due Diligence: A thorough process for high-risk customers |
SDD | Simplified Due Diligence | Simplified due diligence: streamlined procedure for documented low-risk customers |
PEP | Politically Exposed Person | Politically Exposed Person: a person who holds or has held important public offices |
UBO | Ultimate Beneficial Owner | Beneficial Owner: natural person who owns or controls a legal entity (holding >25%) |
AMLCO | AML Compliance Officer | Anti-Money Laundering Compliance Officer: oversees AML/CFT procedures |
FIU | Financial Intelligence Unit | Italian authority that receives Suspicious Transaction Reports (SOS) |
SOS | Suspicious Transaction Report | Communication sent to the UIF when a ML/TF operation is suspected |
OPO | Professional Gold Operator | Entity authorized by the Bank of Italy pursuant to Law 7/2000 to operate in the gold trade |
LBMA | London Bullion Market Association | International association that certifies gold and silver foundries — the gold standard for metal storage |
4. | WHY WE VERIFY YOUR IDENTITY |
Identity verification isn’t just a legal requirement: it’s the primary tool MyGold uses to protect its customers and ensure the integrity of the physical gold market. The primary risk for an OPO operator is being unwittingly involved in illicit activities.
These controls protect both MyGold and—most importantly—our customers, ensuring a safe and reliable environment for investing in physical gold. |
5. | OUR APPROACH: RISK-BASED AND HUMAN-FIRST |
The company adopts a risk-based approach (RBA), in accordance with the FATF/GAFI Recommendations for Precious Metals Operators (updated 2024) and the Bank of Italy’s supervisory provisions for OPOs. This means that:
Our approach combines on-site identification—performed by our resources—with in-depth document verification. This dual level of control ensures high standards for all clients. Clients are classified into three risk categories—LOW, MEDIUM, HIGH—based on factors such as country of residence, type of transaction, and whether they are a PEP or sanctioned entity. The level of verification required is proportionate to the assigned risk category.
6. | HOW WE VERIFY YOUR IDENTITY |
6.1 The KYC Process for Individuals
The identity verification (KYC) process for individual customers always involves direct, in-person contact between the customer and the company. There is no option to complete the KYC process automatically or without human interaction.
The customer presents himself in person at the MyGold operational headquarters SpA or meet with an authorized MyGold consultant . The following documentation is collected for this purpose: a) Valid identity document (identity card, passport, driving license); b) Italian tax code or foreign equivalent;odice Fiscale italiano o equivalente estero; c) Document certifying ownership of a current account in the customer’s name (for bank transfers); d) Proof of residence (recent utility bill or bank statement, no older than 3 months); e) Profession and employer; f) Declaration of any PEP status; g) Documentation on the source of the funds used to purchase the gold (income from employment, business, inheritance, sale of assets, existing liquidity — with supporting documentation). |
6.2 Purpose and Nature of the Commercial Relationship
During the identity verification process, MyGold collects information directly from the customer to understand the purpose and nature of the business relationship. This information includes, but is not limited to:
This information is always collected through direct, in-person interaction with the customer and serves to ensure an adequate risk assessment tailored to the customer’s profile, in compliance with AML/KYC/KYB regulations.
6.3 The KYB Process for Legal Entities
For legal entity clients — companies, corporations, foundations, trusts — the KYB verification process requires additional documentation compared to individual KYC:
Attention — In the absence of sufficient information to identify the Beneficial Owner (UBO), MyGold SpA will not proceed with the activation of the commercial relationship. |
6.3.1 Identification of the Beneficial Owner (UBO)
Pursuant to Article 20 of Legislative Decree 231/2007, MyGold identifies the Beneficial Owner according to the following criteria:
For each identified Beneficial Owner, the company obtains a declaration signed by the legal representative, verifies the identity using the same criteria as for natural persons, and performs screening against PEP and international sanctions lists.
6.4 Absolute prohibition of anonymous relationships
Absolute Prohibition — MyGold does not establish or maintain business relationships with anonymous customers, those with fictitious identities, those who refuse to provide the information required for verification, or those who provide false or contradictory information. If verification is not possible, MyGold will refuse to establish a business relationship and will assess whether there are grounds for filing a Suspicious Transaction Report (SOS) with the FIU. |
7. | HOW WE ASSESS EACH CLIENT’S RISK |
Each client undergoes a risk assessment upon onboarding and periodically throughout the business relationship. The assessment takes into account the following key factors, in accordance with the FATF Recommendations and the Bank of Italy’s supervisory provisions:
Category | Risk factors analyzed |
Customer-related factors | Residence/domicile; nationality; type (private, company, foundation, trust); any PEP status; previous reports or business relationships; consistency between declared profile and transactions carried out |
Geographical factors | Country of residence/domicile; countries of origin of funds; countries classified as high risk by FATF (grey/black list); countries subject to EU, UN, OFAC sanctions |
Operating factors | Amount and frequency of transactions; consistency with declared income and assets; source of funds; type of plan (installment vs. spot); anomalous variations compared to the initial profile |
Factors related to the products and services offered | Origin of the gold delivered; LBMA certifications of the custodian smelters; any gold of unknown or uncertified origin; requests for cash conversion of large amounts |
8. | CUSTOMER VERIFICATION |
Based on the risk assessment, each customer is assigned a proportionate level of verification:
Level | When it applies | What does it entail? |
CDD Standard | Customers with a medium/low risk profile | Full identity verification (KYC/KYB), understanding the purpose of the relationship, periodic monitoring |
Strengthened EDD | High-risk customers | Thorough verification of source of funds and assets, management approval, continuous and intensive monitoring |
9. | POLITICALLY EXPOSED PERSONS (PEP) |
Pursuant to Article 1, paragraph 2, letter dd ) of Legislative Decree 231/2007, a Politically Exposed Person (PEP) is a natural person who holds or has held important public offices. Examples include, but are not limited to:
MyGold , while recognizing the possibility of establishing relationships with PEPs pursuant to current legislation, adopts a prudential policy that provides, in most cases, for the refusal or termination of the relationship, unless otherwise determined by the Compliance Officer.
10. | GEOGRAPHICAL RESTRICTIONS |
MyGold does not accept onboarding customers who are residents, domiciled, or citizens of countries subject to international restrictive measures by the United States, the European Union, or the UN, nor customers who are on OFAC sanctions lists.
Excluded countries (examples) — By way of example and not limited to, the following currently fall into this category: Cuba, Iran, North Korea, Syria, Russia (sanctioned entities), as well as any other country subject to equivalent sanctions regimes by the competent international authorities. |
For customers residing in countries on the FATF gray list or in high-risk countries, MyGold applies enhanced diligence measures (EDD). The establishment of a business relationship is subject to the Compliance Officer’s assessment.
The lists of high-risk and sanctioned countries are consulted and updated on the basis of official publications by:
11. | PERIODIC CUSTOMER PROFILE UPDATE |
Identity verification does not end with onboarding . During the course of the business relationship, MyGold may request updates to customer data and documents in the following circumstances:
In such cases, MyGold may temporarily suspend access to certain services until the verification update is completed. The customer is always informed in advance and transparently of the information requested and the reasons for this. |
12. | SUSPICIOUS TRANSACTIONS AND REPORTING OBLIGATIONS |
The company is required by law (Articles 35-39 of Legislative Decree 231/2007) to report to the UIF any transactions for which it suspects, or has reasonable grounds to suspect, that money laundering or terrorist financing operations are underway.
Confidentiality obligation ( Tipping Off) In the event of a report, it is absolutely forbidden to inform the customer of its existence (confidentiality obligation – tipping off – art. 38 Legislative Decree 231/2007). Therefore, if MyGold SpA should proceed with a report regarding a customer, it will not be able to communicate it to the customer.
Submitting an SOS to the FIU does not in itself constitute an accusation against the customer. The assessment is carried out by the competent authorities. |
13. | YOUR RIGHTS |
As part of AML/KYC/KYB procedures, customers may have questions about the data collected and how it is used. For any information, please contact MyGold ‘s Compliance Officer . However, please remember that:
GDPR Law | Applicability in the AML field |
Right to erasure (Article 17 of the GDPR) | NOT applicable to data processed in compliance with AML obligations, which must be retained for 10 years after termination of the relationship (Article 31 of Legislative Decree 231/2007). |
Right to object to processing (Article 21 GDPR) | NOT applicable to processing based on legal obligation (KYC/KYB/AML). |
Right of access, rectification, portability (Articles 15-20 GDPR) | May be exercised within the limits of AML regulations. Contact: administration@mygold.world |
Complaint to the Supervisory Authority | Always available: Italian Data Protection Authority — www.garanteprivacy.it — Piazza Venezia 11, 00187 Rome. |
Compliance / Privacy Contact | administration@mygold.world |
Website | www.mygold.world — Privacy section |
Registered office | MyGold SpA — Piazzale Cadorna Luigi 9, 20123 Milan (MI) |
Privacy Guarantor (complaints) | www.garanteprivacy.it — Piazza Venezia 11, 00187 Rome |
14. | POLICY UPDATES |
This Policy is subject to annual review by the Compliance Officer and MyGold management. SpA , or upon the occurrence of significant regulatory changes (updates to Law 7/2000, Legislative Decree 231/2007, Bank of Italy provisions, UIF communications).
The updated version is always available on www.mygold.world in the section dedicated to compliance and transparency.
