This Anti-Money Laundering Policy sets out Nivoda’s approach to ensuring that we comply with all applicable laws and regulations to prevent money laundering and appropriately manage money laundering risks.
The main risks associated with the sale of diamonds and jewellery are the following:
- Falsely declaring items in imports. This can be importing additional items over and above the declared invoice, under or overvaluing the items, or shipping fewer items than declared.
- Receipt of illegitimate funds
To combat these risks, we have implemented the following policies and procedures. It is our mission and top priority to facilitate and support legitimate trade in the jewellery industry.
1. Company Policy
It is the policy of Nivoda to actively prevent money laundering in the trade of diamonds and jewellery. Our anti-money laundering policies and procedures have been designed to ensure compliance with regulation and will be reviewed and updated on a regular basis to ensure procedures and controls are in line with both regulation and our business practice.
We ensure that product prices are not engineered to facilitate transfer pricing, tax evasion or money laundering.
3. Quality Control
Our quality control process includes matching all microscopic laser inscriptions on the diamonds to the GIA Certificate (Gemological Institute of America) or any other respective Certificate, and invoice of sale to ensure only legitimate
4. AML Compliance Director Designation and Duties
The firm has designated a Anti-Money Laundering Program Compliance Director (AML Compliance Director), with full responsibility for the firm’s AML program. The duties of the AML Compliance Director includes monitoring the firm’s compliance with AML obligations, ensuring all funds are received from legitimate sources and goods are not over or undervalued.
5. Know Your Customer (KYC) Program
The KYC rules apply to all customers & suppliers who open new accounts with Nivoda.
A. Sign-up process
During the sign-up process, customers are required to fill out a KYC form.
B. Customers who refuse to provide information
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our firm will not open a new account and, after considering the risks involved, consider closing any existing account.
C. Verifying information
We will verify the information within a reasonable time before or after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information.
6. Monitoring Accounts for Suspicious Activity / Transactions
We monitor account activity for suspicious transactions and flags that are appropriate to our business.
The AML Compliance Director will be responsible for this monitoring, will review any activity that our monitoring system detects, and will determine whether any additional steps are required.
When our automated systems or an employee of the firm detects any red flag, or other activity that may be suspicious, he or she will notify the AML Director, who will then decide how to further investigate the matter. This may include gathering additional information from the customer or supplier, internally or from third-party sources, contacting the government, freezing the account or preventing the order(s) from being completed.