AML/CTF Policy

HLBullion (Havilah Liberty Pty Ltd) is a bullion dealer enrolled with AUSTRAC, Australia’s anti-money laundering and counter-terrorism financing regulator. We maintain an AML/CTF program as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and the AML/CTF Rules.

Our approach

We take a risk-based approach to compliance, designed to protect our clients, our business and the integrity of the bullion market. Our processes are built into our systems so that legitimate clients can transact quickly, securely and with minimal disruption.

Identity verification

Australian law requires us to verify the identity of clients for certain transactions. We may also request verification for any transaction, at our discretion.

  • Individuals verify through a secure online process that typically takes a few minutes.
  • Companies, trusts and super funds may need to provide details of their structure and the people who own or control them, along with supporting documents.

Once verified, most clients can transact without being asked again unless their details change or a review is due.

We may ask for further information, such as the source of funds or the purpose of a transaction, where the law or our risk assessment requires it.

Protecting yourself

When we need information from you, we will direct you to our secure Client Portal. HLBullion will never ask you to provide passwords or payment card details by email or text message, or advise a change to our bank account details by message. If you’re unsure whether a message is genuine, don’t respond to it. Contact us directly using the details on our website.

Our right to delay or decline

We may delay, suspend or decline any transaction, or end any client relationship, where:

  • we cannot complete our due diligence,
  • information provided is incomplete or cannot be verified, or
  • we consider it necessary to meet our legal obligations.

We may be legally prevented from giving reasons. To the extent permitted by law, HLBullion is not liable for any loss arising from a delay, suspension or refusal made in good faith to comply with our AML/CTF obligations, including loss from changes in metal prices.

Reporting obligations

We report to AUSTRAC as required by law. Regulatory reporting is confidential.

Privacy

Information collected for verification is used to meet our legal obligations and to provide our services. It is stored securely with restricted access, and retained for the period required by law. Please see our [Privacy Policy] for how we collect, use and protect personal information.

Changes to this policy

We may update this policy at any time without notice. The current version is always available on this page.

This policy is a general summary and is not legal advice. It does not form part of any contract or create obligations beyond those required by law.