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Compliance Policies

Legal compliance and commitment to international standards

MASAK Compliance

Law No. 5549 on Prevention of Laundering Proceeds of Crime

Obligations Under Law No. 5549

Yaman Precious Metals operates as an obligated entity under Law No. 5549 on the Prevention of Laundering of Proceeds of Crime. Our company fully complies with all rules and regulations set by MASAK (Financial Crimes Investigation Board). Our internal policies are continuously updated in accordance with the Measures Regulation, General Communiques, and MASAK guidance documents.

Customer Due Diligence (KYC)

Under our customer identification and verification processes, beneficial ownership determination, and information gathering obligations at the start of business relationships, all our customers' identity information is meticulously verified. Turkish citizens provide their National ID Number, foreign nationals provide passport information, and legal entities submit trade registry records. Continuous customer monitoring and updated information verification procedures are applied.

Suspicious Transaction Reports (STR)

Our company is obligated to report all suspicious transactions to MASAK. Our employees receive regular training on suspicious transaction indicators. Reports are made within the framework of confidentiality principles, and under no circumstances is information disclosed to the relevant customer or third parties when a STR has been filed.

Threshold Transaction Reporting

For cash transactions of TRY 85,000 and above, customer identification is mandatory and relevant reports are submitted to MASAK. This threshold is applied to mitigate money laundering risks in precious metals trading. Transaction structuring attempts are also evaluated within the scope of suspicious transactions.

Record Keeping Obligations

All customer identification information, transaction records, and documents are retained for a minimum of 8 years as required by law. These records are kept ready for immediate submission when requested by MASAK, and our digital and physical archiving systems are managed in compliance with international data security standards.

Internal Audit and Compliance Program

A MASAK compliance officer has been appointed in our company, and employees receive regular AML/CFT (Anti-Money Laundering / Counter-Financing of Terrorism) training. Internal control mechanisms are periodically reviewed, and independent internal audit reports are prepared annually. Our compliance program is always ready for MASAK inspections.

Risk-Based Approach

Customer risk assessments are conducted, and enhanced due diligence measures are applied for high-risk customers. PEP (Politically Exposed Persons) screening is performed regularly, with dynamic risk scoring based on geographic risk factors and transaction volumes.

Sanctions Screening

UN, EU, and Turkey sanctions lists are regularly monitored, and all customers and business partners are screened against sanctions lists. Comprehensive screening procedures including the OFAC (US Treasury) sanctions list are applied.

Precious Metals Import Regulations

Under the Precious Metals Import License issued by the Republic of Turkey Ministry of Trade, full compliance with Decree No. 32 on the Protection of the Value of Turkish Currency and related communiques is maintained. Customs legislation, foreign exchange regulations, and Borsa Istanbul Precious Metals Market rules are fully applied in import operations. All documentation processes for standard and non-standard precious metals imports are conducted within the legal framework.

Counter-Financing of Terrorism (CFT)

Our company fully complies with national and international regulations on the prevention of terrorism financing. All customers and transactions are screened against sanctions lists prepared under UN Security Council resolutions. In case of a match with terrorist organization lists, notification is made to the competent authorities without delay.

Personal Data Protection (KVKK)

Under Law No. 6698 on the Protection of Personal Data, customer and employee personal data is processed and protected at the highest security standards. Data processing activities are conducted transparently within the framework of the notification obligation, and explicit consent mechanisms are effectively implemented. Full compliance with the decisions of the Personal Data Protection Board (KVKK) is maintained.

International Standards

LBMA

LBMA Compliance

We comply with the London Bullion Market Association Responsible Gold Guidance standards and conduct operations according to Good Delivery standards. Supply chain due diligence processes are documented in accordance with LBMA requirements.

OECD

OECD Due Diligence

The five-step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas is fully implemented. Supplier evaluation and monitoring procedures are conducted in accordance with this guidance.

FATF

FATF Recommendations

Full compliance with the Financial Action Task Force (FATF) recommendations on combating money laundering and terrorist financing is maintained. Our internal policies are continuously updated within the framework of the 40 FATF recommendations, and international best practices are followed.

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