The Tanzanian Anti-Money Laundering Act, 2006 prohibits legal and natural persons from engaging in transactions which involve the proceeds of crime, or from assisting others to do so. We as GG Refinery comply with this Act by implementing respective procedures and policies that ensure reporting of any suspicious transactions to the Financial Intelligence Unit (FIU).

GG Refinery has established a questionnaire that intends to assist in its respective supply chain due diligence on acquiring information in regarding the AML and  CFT policies and procedures implemented by the respective customers, professional intermediaries, correspondent banks, consultants, and non-governmental organizations.

This questionnaire has been established in a manner that covers KYC aspects for individual miners (specifically small-scale miners without an institution), miners with an institution (medium- and large-scale miners with companies) and bank institutions operating within Tanzania. Based on the type of miner in question, the established questionnaires have been primarily divided into two parts. The first part addresses general entity related information whereby all the personal/company details and addresses, operational licenses, ownership structure, origin of the mineral (gold) (including name and place of the mine) and relevant evidences are captured. The second part of this questionnaire addresses the customer’s/client’s AML/CFT policies and procedures. Here, the general AML policies, practices and procedures, risk assessment, KYC, general and enhanced due diligence, reportable transactions and prevention, as well as detection of transactions with illegally obtained funds, transaction monitoring, AML training details, and relevant evidences are captured.

To ensure compliance with applicable AML and CFT laws and regulations, GG Refinery’s KYC/AML/CFT policy is designed to also consider the framework:

1. For the detection, reporting, and handling of suspicious transactions as per GG Refinery’s Suspicious Transactions Policy and Procedure which also incorporates a “no cash” transaction policy when interacting with customers. This Suspicious Transactions Policy and Procedure also includes regularly screening all counterparties against global sanction lists where any matches or potential matches should be reported to the government authorities as suspicious and investigated accordingly.
2. Furthermore, GG Refinery is committed to upholding the highest standards of integrity, transparency, and responsible business practices in line with the Responsible Minerals Initiative (RMI), London Bullion Market Association (LBMA), as well as other international standards and guidelines. This policy also references and incorporates GG Refinery’s policy on Politically Exposed Persons (PEPs) to mitigate potential risks in association with AML and CFT.