Anti-Money Laundering Compliance Program

Alpha Omega Gold
Effective Date: May 6, 2025

Adoption of Compliance Plan

The purpose of this Anti-Money Laundering (AML) Compliance Program is to establish a comprehensive framework to combat money laundering, terrorist financing, corruption, and other financial crimes.

Alpha Omega Gold is committed to continuously reviewing and enhancing its AML strategies and maintaining a robust and effective AML program. We uphold the highest standards of compliance and require all management, employees, and agents to fully adhere to these standards to prevent the misuse of our products and services for illicit purposes.

Policy Adherence and Legal Compliance

Strict adherence to this policy is essential to ensure compliance with all applicable AML legislation. Alpha Omega Gold complies with the minimum standards outlined in relevant laws, regulations, and guidance issued by regulatory bodies. These standards outline the core statutory obligations imposed on our organization.

Employee Training

A foundational element of our compliance program is mandatory employee training. This includes:

• Identifying suspicious activity and structured transactions
• Recordkeeping and reporting requirements
• Verification of customer identity
• Understanding AML laws and responsibilities

All employees must read this manual and sign an Acknowledgement of Employee Training, which will be retained in their personnel or AML compliance files.

Understanding Money Laundering

Money laundering is defined as the attempt to disguise or conceal the origin, ownership, control, or source of illegally obtained funds.

Three Stages of Money Laundering:

1. Placement: Introducing illicit funds into the financial system through methods such as money orders, traveler’s checks, prepaid cards, or wire transfers.
2. Layering: Moving funds through multiple transactions and institutions to obscure their origin.
3. Integration: Converting laundered funds into legitimate assets, such as real estate, vehicles, or businesses.

OFAC Compliance

The Office of Foreign Assets Control (OFAC) under the U.S. Department of the Treasury enforces economic and trade sanctions. Alpha Omega Gold strictly prohibits transactions involving individuals or entities listed on OFAC’s Specially Designated Nationals (SDN) list. A current list is available at: www.treasury.gov/resource-center/sanctions

Suspicious Transactions

Employees must be trained to detect potentially suspicious activity, including but not limited to:

• Unusual payment methods (e.g., large cash transactions, sequential money orders)
• Reluctance to provide complete identification or contact information
• Excessive secrecy in transactions
• Transactions inconsistent with standard customer behavior or industry norms

Employees must:

• Obtain valid identification for all transactions
• Report cash transactions over $10,000 via IRS Form 8300
• Report suspicious transactions promptly to the appropriate authorities

Alpha Omega Gold will fully cooperate with the Financial Crimes Enforcement Network (FinCEN), IRS, and other regulatory agencies as required.

Designation of Compliance Officer

Alpha Omega Gold formally designates a qualified Compliance Officer responsible for implementing and maintaining this AML Program. The Compliance Officer will:

• Ensure the AML program is effectively enforced and updated
• Monitor compliance with applicable laws and internal procedures
• Ensure appropriate training is provided to relevant personnel
• Oversee periodic independent reviews of the program

Independent Review

In accordance with the USA PATRIOT Act, Alpha Omega Gold must conduct an independent review of its AML program. This review may be performed by a qualified employee (not the Compliance Officer) or an external expert familiar with AML requirements for precious metals dealers.

The frequency and depth of the review must reflect the level of money laundering and terrorist financing risks associated with the business, which includes:

• Types of products sold
• Customer and supplier profile
• Distribution methods and geographic exposure
• Transaction routing through high-risk jurisdictions

USA PATRIOT Act Compliance

Alpha Omega Gold’s AML program meets the requirements of the USA PATRIOT Act and includes:

1. Internal Policies and Controls
   Policies tailored to our business’s specific risks and procedures for compliance with the Bank Secrecy Act (BSA).
2. Compliance Officer Designation
   A dedicated officer responsible for AML enforcement, updates, training, and reporting.
3. Employee Training
   Ongoing education on AML requirements and suspicious activity recognition.
4. Independent Program Review
   Periodic, objective reviews to assess program effectiveness and regulatory adherence.