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ACE herein is fully committed to support their customers, suppliers and agents in being ‘Conflict-Free’ compliant by implementing appropriate ‘known origin’ systems.


The World Gold Council has developed the Conflict-Free Gold Standard, an industry-led approach to combat the potential misuse of mined gold to fund armed conflict. The Standard has been developed with its member companies, comprising the world’s leading gold producers, and with extensive input from governments, civil society and supply chain participants. It is hoped that the Standard will promote responsible mining practices throughout the gold mining industry. It is an open standard that is available for use by any party involved in the extraction of gold.


Responsibly undertaken, gold mining can play an important role in contributing to sustainable development and alleviating poverty in many of the world’s developing countries. The direct and indirect economic contribution of professional gold mining creates new possibilities for these nations, their communities and individuals.


However, when there is armed conflict, even the best managed operation will need to take additional steps to ensure that both the gold it produces and its broader activities do not contribute to the conflict.


Where a company can demonstrate that it is operating in an area assessed to be ‘conflict-affected or high-risk’ in a way that does not support or benefit unlawful armed conflict, it should be encouraged to continue its operations. Indeed, the closure or suspension of a major source of employment and government revenue may accentuate the crisis.


Gold produced in conformance with the Conflict-Free Gold Standard will provide confidence that it has been extracted in a manner that does not cause, support or benefit unlawful armed conflict or contribute to serious human rights abuses or breaches of international humanitarian law. The Standard is based upon internationally recognized benchmarks and conformance will be subject to external assurance. It has been widely recognized as credible and workable.


ACE herein cooperate with, and enhance worldwide efforts to ensure that precious metals come from legitimate, ethical sources, and that they are and have not been associated with crime, armed conflict or human rights abuse.

Our policy aims to do business with law-abiding and legitimate customers only, and to deny our product and services to all others.


This policy, and the program and due diligence procedures that implement it, are founded upon our general standards of business conduct.


As a result we are committed to :

     •  Conducting our business in a culture of honesty and opposition to fraud and corruption;

     •  Maintaining high moral, ethical and social standards in our business and activities;

     •  Maintaining proper business relationships with all individuals, including government officials and employees.


We implement this policy throughout the firm and are committed to the following code:


1. We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of :

     • torture, cruel, inhuman and degrading treatment;

     • forced or compulsory labour; • the worst forms of child labour;

     • human rights violations and abuses;

     • war crimes, violations of international humanitarian law, crimes against humanity or genocide.


2. We will not deal with, and will immediately discontinue engagement with, upstream suppliers where we identify a reasonable risk that they are committing, or are sourcing from or linked to any party committing, abuses described above.


3. We will not tolerate support, direct or indirect, to non-state armed groups, including but not limited to, procuring precious metals from making payments to or otherwise providing assistance or equipment to, non-state armed groups or their affiliates who illegally control mine sites, transportation routes, points where precious metals are traded and upstream participants in the supply chain; and/or tax or extort money or precious metals at mine sites, along transportation routes or at points where they are traded, or from intermediaries, export companies or international traders.


4. We will not deal with, and will immediately discontinue a relationship with, upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as described above.


5. We maintain that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide support, may it be direct or indirect, to public or private security forces that commit abuses or that act illegally as described above.


6. We will not attempt to influence improperly others or offer, promise, give or demand bribes or kickbacks in any form. We will resist their solicitation, and will not permit Company funds, assets or property to be used to benefit any individuals, including government officials, customers, contractors and suppliers illegally or in ways that violate this policy.


7. We do not and will not disguise the origin of precious metals, or misrepresent taxes, fees and royalties paid to governments for the purposes of extraction trade, handling, transport and export of gold.


8. We support efforts and contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade handling, transport or export of precious metals. We require our employees, agents, consultants, and business partners to comply with this policy, and will enforce it with appropriate disciplinary measures, up to and including termination of employment or contracts.


CONTACT INFORMATION If you have any questions or concerns regarding this policy, or its implementation please contact:

AML / CFT Policy and Procedures

Introduction and Scope


As with any financial services company, there is a risk that products and services offered by ACE might be used to launder money and finance terrorism. UAE law and applicable local laws in the jurisdictions in which we operate, requires us to put training, processes and systems in place to identify, manage and mitigate this risk. We do this to protect the Group’s reputation, to comply with relevant laws and to be a responsible corporate citizen. Failure to do so may result in social harm, significant penalties, including legal and regulatory action.


Our AML/CFT Policy


Our policy sets out how ACE complies with its legislative obligations. This applies to all business divisions and employees (permanent, temporary and third-party providers) working for ACE in UAE and overseas.




Money laundering is the process of hiding or disguising the source of illegally obtained (“dirty”) funds to make them appear legitimate (“clean”), e.g. by filtering them through the financial system.


Money laundering reduces the risk of detection and confiscation by authorities. It is just as serious as the criminal activity behind it – and preventing it can help reduce crime.


Terrorism financing differs from money laundering in 3 main ways :

Its primary purpose is to disguise the ultimate use of the funds, as opposed to their origin,


It can involve relatively small sums of money, which can have a huge impact in terms of death, destruction and disruption, Although terrorists may finance their activities through crime, legitimate funds can also be misappropriated to finance terrorism.


Customer Identification


UAE and European AML regulations provide a list of ‘designated services’. Before receiving any of these designated services, customers will be required to provide proof of identity or similar documentation.


ACE is required to collect and verify this information, depending on the type of customer :

Personal - an individual person of any nationality ;

A sole trader - a person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business;


A domestic company- incorporated in Switzerland, including proprietary, public and listed public companies;


A foreign company incorporated outside UAE;


A partnership - a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit;


A trust - a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company;


An association - a group of persons who have agreed to join together in pursuit of one or more common objectives.


An association can be incorporated or unincorporated;


A Registered co-operative - a legal entity owned and controlled by the people for whom it was established and who benefit from using its services;


A Government body – this can be a domestic or foreign government body.


Please note that ACE complies with the National Privacy Principles and DMCC code of obligations.




Money laundering and terrorism financing (ML/TF) are sometimes detected because a customer acts or behaves in a suspicious way. For a ‘suspicion’ to be valid, we must have reasonable grounds to believe ML/TF activity may be occurring.


To support this, employees receive training in identifying and reporting suspicious matters.


ACE 5 key AML/CTF principles


1. Comply with AML/CTF legislation in the countries we operate in.


2. Strive to fulfill international standards as detailed in the recommendations of the Financial Action Task Force


3. Work in conjunction with the UAE Government and the governments of the countries we operate in, and support their objectives in relation to the prevention, detection and control of ML/TF.


4. ACE may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate social responsibility.


5. Maintain and comply with an AML/CTF program, as required by DMCC AML/CTF legislation.


Policy Roles and Responsibilities


ACE, Directors and Senior Management have ongoing oversight of our AML/CTF policy and procedures. All permanent and temporary employees must comply with these, attend training specific to their role, and report suspicious matters or behaviors.


ACE AML/CTF  Program


The design and implementation of the program was tailored to our ML/TF risk profile, applying specific systems and controls, including:


     • ML/TF risk assessment,

     • Employee training,

     • Employee and customer due diligence,

     • Transaction monitoring.


Monitoring and Reporting


We also may report the following information to either DMCC, regulator or ARIF, the private non-profit association of public utility, whose purpose is to assist in the prevention of and the fight against Money laundering in relation with the DMCC, UAE Government Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector (MLA):


     • Transactions with a cash component of USD 100,000 - or more.

     • Electronic transfers of funds into or out of UAE

     • Any transactions or other activities regarded as suspicious.


For any further question please contact our compliance team.

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