SABIKA GOLD – ANTI-MONEY LAUNDERING (AML) & COMBATING THE FINANCING OF TERRORISM (CFT) POLICY

Last Updated: 1 September 2025

1. INTRODUCTION & DEFINITIONS

Sabika Gold (“Company”, “we”, “us”) is a non-bank financial institution operating a digital gold savings and investment platform in the Kingdom of Saudi Arabia. While we are not a licensed bank, we recognize our obligation to prevent misuse of our platform for money laundering, terrorist financing, or other illicit activity.

2. LEGAL & REGULATORY FRAMEWORK (SAUDI ARABIA)

Sabika Gold adheres to Saudi laws and regulatory expectations, including:

• Anti-Money Laundering Law (2017, Royal Decree M/20) and its Implementing Regulations.
• Counter-Terrorism and Terrorism Financing Law (2017, Royal Decree M/21).
• Saudi Central Bank (SAMA) Guidelines on AML/CFT for Non-Bank Financial Institutions.
• Capital Market Authority (CMA) Rules on securities-like products.
• Personal Data Protection Law (PDPL, 2021).
• International standards from the Financial Action Task Force (FATF) and MENAFATF.

As a non-bank financial institution, Sabika Gold is not subject to the full banking AML framework but voluntarily adopts proportionate AML/CFT measures appropriate to its risk exposure.

3. SABIKA GOLD COMMITMENT STATEMENT

Sabika Gold is committed to:

• Zero tolerance for money laundering, terrorism financing, or illicit activities.
• Cooperating with Saudi authorities (SAMA, CMA, FIU, law enforcement).
• Implementing proportionate risk-based controls for customer due diligence (CDD), monitoring, and reporting.
• Protecting our users, partners, and Saudi Arabia’s financial integrity.

4. SCOPE

This policy applies to:

• All Sabika Gold employees, contractors, and agents.
• All customers using Sabika Gold’s platform.

5. KEY PROCEDURES

5.1 Customer Identification & KYC

• All users must complete Know Your Customer (KYC) before transacting.
• Required data: full name, National ID/Iqama, mobile number, and verified bank/payment method.
• No anonymous or unverified accounts allowed.

5.2 Risk-Based Approach

• Customers are risk-rated: Low, Medium, or High.
• Enhanced Due Diligence (EDD) applies to:
• Politically Exposed Persons (PEPs).
• Users from high-risk jurisdictions (as per FATF/SAMA lists).
• Unusual or complex transaction patterns.

5.3 Transaction Monitoring

Automated monitoring tools detect:

• Large/unusual transactions.
• Structuring (splitting deposits).
• Rapid buy-sell patterns inconsistent with user profile.

Red-flagged activity is escalated to Compliance.

5.4 Reporting Suspicious Activity

• Suspicious Activity Reports (SARs) filed to the Saudi Financial Intelligence Unit (FIU).
• No tipping-off customers of ongoing investigations.

5.5 Record Keeping

KYC and transaction records retained for minimum 10 years (as required under Saudi AML law).

6. TRAINING & AWARENESS

• All employees receive AML training at onboarding and annual refreshers.
• Training covers: red flags, reporting obligations, and Saudi legal requirements.

7. COMPLIANCE RESPONSIBILITY

Sabika Gold appoints a Money Laundering Reporting Officer (MLRO) responsible for:

• Reviewing flagged activity.
• Filing SARs with the FIU.
• Ensuring compliance with SAMA/CMA rules.

8. PERIODIC REVIEW

• This policy will be reviewed annually or upon regulatory change.
• Updates require approval by senior management and the Compliance Officer.

9. LIMITATIONS & PROPORTIONALITY

As a non-bank financial institution, Sabika Gold:

• Does not hold customer deposits.
• Only facilitates transactions backed by physical allocated gold.
• Applies simplified AML measures while maintaining regulatory compliance.

10. CONTACT

For AML compliance concerns, contact:

• 📧 compliance@sabikagold.com
• Riyadh, Kingdom of Saudi Arabia