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AML/CFT Policies & Procedures

February 2, 2026 by
AML/CFT Policies & Procedures
COMFI


Our operational framework for customer due diligence, transaction monitoring, reporting, and financial crime prevention.

Comfi Trading FZCO maintains AML/CFT Policies & Procedures designed to prevent, detect, and mitigate risks relating to money laundering, terrorist financing, illegal organisations, proliferation financing, sanctions evasion, and other financial crime risks.

As a company active in non-manufactured precious metal trading, Comfi Trading FZCO recognises that the precious metals sector requires strong controls, careful counterparty assessment, and clear internal procedures. The company’s AML/CFT framework supports responsible business conduct and helps ensure that transactions are carried out with transparency, traceability, and compliance awareness.


The policy manual sets out the company’s approach to:

  • customer identification and verification;
  • Know Your Customer procedures;
  • Customer Due Diligence and Enhanced Due Diligence;
  • beneficial ownership identification;
  • risk assessment and customer risk classification;
  • politically exposed persons screening;
  • sanctions and watchlist screening;
  • monitoring of customer activity and transactions;
  • identification of red flags and suspicious activity indicators;
  • reporting of suspicious transactions through appropriate regulatory channels;
  • supplier due diligence;
  • employee screening, training, and awareness;
  • cash transaction controls;
  • record retention;
  • independent compliance review;
  • customer exit procedures;
  • confidentiality and tipping-off prevention.

Comfi’s AML/CFT procedures are based on a risk-based approach. This means that customers, counterparties, products, jurisdictions, delivery channels, and transaction patterns are assessed according to their level of risk. Where higher risks are identified, the company applies enhanced measures, additional verification, senior-level review, and closer ongoing monitoring.

The policy also reflects the importance of maintaining accurate and updated customer information. Comfi reviews customer records, monitors business relationships, and applies additional controls where transactions appear unusual, complex, inconsistent with the customer profile, or linked to higher-risk jurisdictions.

In line with its internal compliance programme, Comfi Trading FZCO provides AML/CFT training and awareness to relevant employees. Staff are expected to understand their responsibilities, identify suspicious activity indicators, escalate concerns internally, and respect confidentiality requirements.

The company also maintains procedures for record-keeping, internal review, regulatory reporting, and protection against retaliation for good-faith reporting. These measures support a culture of compliance and accountability across the organisation.

Comfi Trading FZCO is committed to conducting its precious metals trading activities with integrity, transparency, and professionalism. Its AML/CFT Policies & Procedures form part of the company’s wider governance and compliance framework and support its objective of maintaining responsible, traceable, and compliant bullion trading operations.

AML/CFT Governance Framework