Our governance approach to anti-money laundering, counter-terrorist financing, and sanctions compliance.
Comfi Trading FZCO maintains an AML/CFT Governance Framework designed to support a strong culture of compliance, accountability, and responsible business conduct within the precious metals sector.
As a Designated Non-Financial Business and Profession, Comfi Trading FZCO applies risk-based controls to prevent the misuse of its business activities for money laundering, terrorist financing, proliferation financing, sanctions evasion, or other financial crime risks.
The framework defines the company’s internal governance structure, roles, responsibilities, oversight mechanisms, and reporting obligations. It is built around clear accountability, senior management involvement, employee awareness, customer due diligence, monitoring, record-keeping, suspicious activity reporting, and independent review.
Comfi’s AML/CFT governance approach includes:
- adopting a risk-based compliance framework;
- assessing entity-wide and customer-specific risks;
- applying Customer Due Diligence and Enhanced Due Diligence where required;
- appointing a Compliance Officer responsible for AML/CFT oversight;
- screening and training relevant employees;
- monitoring transactions and identifying suspicious activity indicators;
- reporting suspicious activity through the appropriate regulatory channels;
- maintaining accurate records of business relationships and transactions;
- complying with applicable sanctions obligations;
- reviewing and improving the effectiveness of the compliance programme.
The framework also sets out responsibilities for ownership, management, the Compliance Officer, the Money Laundering Reporting Officer, and front-line employees. This ensures that AML/CFT compliance is not treated as a single function, but as a shared responsibility across the organisation.
Comfi Trading FZCO is committed to conducting its bullion trading activities with transparency, professionalism, and integrity. The company expects all employees and representatives to follow internal policies and regulatory obligations, and it maintains disciplinary procedures for non-compliance.
This public summary reflects Comfi’s commitment to maintaining effective AML/CFT governance and supporting responsible, traceable, and compliant precious metals trading.