AML/CTF Policy

ANTI MONEY LAUNDERING AND COUNTER TERRORISM FINANCING POLICY

At HLBullion, we recognise that trust is earned through integrity, transparency, and strong compliance standards. As a professional bullion dealer operating in South Australia, we are fully committed to meeting our obligations under Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) framework.

We are formally enrolled and registered with AUSTRAC, Australia’s financial intelligence agency and regulator responsible for preventing money laundering and terrorism financing. Our AML/CTF Program has been developed in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, the AML/CTF Rules, and AUSTRAC guidance applicable to bullion dealers.

OUR COMMITMENT TO COMPLAINCE

Our AML/CTF framework is designed to prevent our business from being misused for illicit purposes, protect the integrity of the Australian financial system, safeguard our clients and community, and maintain the highest professional and ethical standards.

We take a proactive, risk-based approach to compliance. This means we continually assess and manage potential risks associated with client types, transaction patterns, delivery channels, and geographic exposure. Our systems are structured to identify, mitigate and appropriately respond to risk while maintaining an efficient and professional client experience.

CLIENT IDENTIFICATION & DUE DILLIGENCE

To ensure we know who we are transacting with, we apply structured Client Due Diligence (CDD) procedures. These processes include verifying identity, confirming beneficial ownership where relevant, and understanding the nature and purpose of transactions.

For higher-risk scenarios — such as complex ownership structures or politically exposed persons (PEPs) — we apply Enhanced Due Diligence (ECDD) measures. We also conduct ongoing monitoring to ensure transactions remain consistent with a client’s known profile. Where required, we request additional information to maintain compliance with regulatory standards.

These measures are not designed to create inconvenience, but to protect legitimate clients, strengthen the integrity of the bullion market, and ensure we meet our legal obligations responsibly.

GOVERNANCE & OVERSIGHT

Responsibility for AML/CTF compliance sits at director level. We have appointed a dedicated AML/CTF Compliance Officer who acts as our liaison with AUSTRAC and oversees reporting obligations, internal controls, and regulatory updates .

Our program includes ongoing risk assessment, transaction monitoring controls, secure record-keeping systems, and structured reporting procedures. We also conduct independent reviews of our AML/CTF program at appropriate intervals to ensure its effectiveness and continued alignment with regulatory requirements.

This layered governance approach ensures accountability, transparency, and continuous improvement.

REPORTING & REGULATORY COOPERATION

Where required by law, we submit reports to AUSTRAC within prescribed timeframes, including Threshold Transaction Reports and Suspicious Matter Reports where applicable . We maintain strict confidentiality in relation to regulatory reporting and comply with all statutory obligations.

SECURITY, PRIVACY & PROFESSIONAL STANDARDS

We understand that clients purchasing bullion value discretion, privacy, and security. All client information is handled securely and stored in accordance with legislative requirements, with access strictly controlled.

Importantly, we do not transact in cryptocurrency and we do not facilitate international funds transfer services, reducing exposure to higher-risk channels .

When you transact with HLBullion, you can do so knowing that we operate under a documented and professionally structured AML/CTF Program, are registered with AUSTRAC, and are committed to ethical, compliant bullion trading practices. Our objective is to provide a secure and professional environment where clients can acquire precious metals with confidence and peace of mind.