Anti Money Laundering & Counter Terrorist Financing

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Anti Money Laundering & Counter Terrorist Financing
(AML/CFT) Policy – RJC COP 2024

Company NameMahavir Bullion & Refinery Private LimitedPolicy No.MBR/AML-CTF/02
Policy TitleAnti Money Laundering & Counter Terrorist FinancingRevision Date01/04/2026
Effective Date01/04/2025Review Date01/04/2027
Approved ByBoard of DirectorsApproval Date01/04/2026
Policy OwnerCompliance Officer / Senior ManagementClassificationControlled Document
Applicable StandardRJC COP 2024Next ReviewAnnually
ProvisionPolicy control
COP 2Management systems, implementation and grievance/escalation integration
COP 5Business-partner controls and expectations
COP 7Risk-based responsible-sourcing due diligence where AML/CFT risks overlap with supply-chain risks
COP 12.1Documented KYC procedures for relevant suppliers/customers and other materials intended to become COP RJC Scope Materials
COP 12.2Enhanced KYC for relevant refining/processing on behalf of third parties and consignment arrangements
COP 12.3Assignment of senior authority and responsibility
COP 12.4Training, documentation and regular review of KYC procedures
COP 12.5Cash/cash-like transaction records and reporting at the applicable threshold
RoleResponsibility
Board of DirectorsApprove the Policy; provide oversight and resources; review material AML/CFT issues and compliance performance at least annually.
Principal OfficerBe the designated senior person responsible for implementation of the AML programme; receive and analyse suspicious-transaction alerts; make statutory reports where required; maintain confidentiality and prevent tipping-off; ensure appropriate training and internal review.
Compliance OfficerConduct/review due diligence; coordinate KYC/KYB; perform sanctions and adverse-information screening; assign/monitor risk classification; oversee transaction monitoring and escalation.
Sourcing & ProcurementComplete required KYC/KYB before onboarding; collect source/origin information; ensure documentation is complete; identify and escalate anomalies.
FinanceUse approved banking channels; monitor payment patterns; maintain financial records; escalate unusual payment behaviour.
Operations / Refinery / LogisticsMaintain appropriate physical and transaction records; reconcile material and documentation; escalate discrepancies and suspicious circumstances.
All EmployeesComply with this Policy; complete required training; immediately report suspicious behaviour or attempted circumvention to the Principal Officer or Compliance Officer.
Prepared ByReviewed & Approved By
Compliance OfficerDirector
Rushikesh Rajendra DeshmukhJitendra Panditrao Deshmukh
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