AML & KYC

Anti Money Laundering & Know Your Costumer

1. Purpose and Scope
This policy outlines the legal and internal measures of Christiaan Robert (hereinafter “the Company”) to prevent money laundering and terrorist financing, in accordance with the Dutch Wwft, Sanctions Act, and relevant EU directives.
Scope: All activities conducted via https://www.christiaanrobert.com, including the purchase, sale, procurement, storage, and shipping of gold/precious metals.

​

2. Laws and Regulations

• Wwft (Anti-Money Laundering and Anti-Terrorist Financing Act)

• Sanctions Act 1977

• EU AMLD v3 and its successors

• FIU-Netherlands guidelines and reporting obligations

• ​

3. Customer Due Diligence (CDD)
For all transactions of € 9,900 or more, or in case of elevated risk:
Identification:

• Natural persons: name, date of birth, address, ID number via passport/driver’s license

• Legal entities: company name, registered address, Chamber of Commerce number, UBO details

Verification:

• Document verification (copy of ID, Chamber of Commerce extract, UBO declaration)

Risk assessment: low, medium, high (based on PEP status, country, nature/amount of transaction)

Underlying checks:

• Politically Exposed Persons (PEPs)

• EU/UN sanctions lists

• UBO checks for legal entities

Document the CDD outcome in the customer file.

​

4. Risk Analysis
Updated annually and includes:

• Customer type (individual, business, foreign customer)

• Transaction value and method (cash, bank transfer)

• Country risk (high-risk countries or jurisdictions)

• Distribution channel (online sales, shipping)

Regular evaluations for updates.

​

5. Monitoring & Detection
For transactions ≥ €9,900 (non-cash): customer identification, CDD, and registration required.
Check for unusual/incorrect data, structures/round-tripping, or originator declarations.
Document unusual patterns (e.g., frequent large transactions, changing UBO details).

​​

6. Reporting Obligation
If suspicious transactions or money laundering are suspected:

• Report to FIU-Netherlands within 3 working days using the reporting form

• Suspend the transaction pending FIU feedback

​

7. Sanctions and PEP Screening
Actively screen clients against EU and UN sanctions lists before onboarding.
Automatic screenings during transactions.
PEPs are subject to enhanced monitoring (stricter CDD, limited product offerings, regular reverification).

​

8. Instructions & Reporting Line
Compliance Officer:
a) ultimately responsible for AML
b) point of contact for FIU & regulators

Responsible staff: report issues with identification or transactions

Training & Awareness:

• In case required, AML/Wwft course for all client-facing staff

​

9. Document Management & Retention
All CDD documents, risk assessments, suspicious activity reports, and transaction data:
retained for a minimum of 5 years after the last contact.
Secured via encrypted storage (cloud or local in line with GDPR).

​

10. Procedures for Changing Customer Profiles
Reassessment required for:

• New/additional services

• Increased transaction volume

• PEP or sanctions list flags

For high risk: the relationship may be restricted or terminated.

​

11. Technical and Organisational Measures
Encrypted website (HTTPS/TLS) + secure customer login