Legal & Compliance Framework for LAMIE

Introduction

LAMIE is committed to adhering to all applicable laws and regulations in the physical trading of precious metals, including gold, silver, platinum, and palladium. This document outlines the legal and compliance obligations and practices that ensure the integrity, transparency, and ethical conduct of our operations.

Regulatory Compliance

1. Local Regulations

LAMIE will comply with all relevant local laws in Iraq, including but not limited to:

- Trade and commerce regulations.

- Anti-money laundering (AML) and counter-terrorism financing (CTF) laws.

- Consumer protection laws.

- Precious metals trading regulations.

2. International Standards

LAMIE aligns its operations with international best practices and standards, including:

- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

- FATF (Financial Action Task Force) recommendations on AML/CTF.

- ISO 9001 for quality management systems.

3. Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF)

- Customer Due Diligence (CDD)

LAMIE will perform due diligence on all clients, including verifying identities, assessing the risk of money laundering, and understanding the purpose of the transactions. Enhanced due diligence will be conducted for high-risk customers.

-Transaction Monitoring

All transactions will be monitored for suspicious activities. Any transactions that appear unusual or suspicious will be reported to the relevant authorities as required by law.

- Record Keeping

LAMIE will maintain records of all transactions, customer information, and due diligence processes for a minimum of five years, as mandated by law.

4. Ethical Sourcing

- Responsible Sourcing

LAMIE will ensure that all precious metals are sourced responsibly, with a commitment to avoiding materials that contribute to conflict or human rights abuses.

- Supplier Due Diligence

All suppliers will be subject to a rigorous vetting process to ensure compliance with our ethical sourcing policies. Suppliers must provide documentation proving the legitimacy and ethical standards of their sourcing.

5. Consumer Protection

-Transparency

LAMIE is dedicated to providing transparent pricing and clear information about the products we trade. Customers will be informed about the purity, weight, and origin of the metals they purchase.

- Fair Trading Practices

All trading practices will be conducted with fairness and integrity. LAMIE will not engage in deceptive, fraudulent, or unfair business practices.

- Dispute Resolution

A clear process will be established for handling customer complaints and disputes. LAMIE will work to resolve all issues promptly and fairly.

6. Data Protection and Privacy

-Data Security

LAMIE is committed to protecting customer data. All personal and transaction data will be secured with the latest encryption technologies and only accessible by authorized personnel.

- Privacy Policy

LAMIE will maintain a clear and accessible privacy policy outlining how customer data is collected, used, stored, and protected.

7. Compliance Monitoring & Auditing

-Internal Audits

Regular internal audits will be conducted to ensure compliance with all applicable laws, regulations, and company policies.

-Third-Party Audits

LAMIE will engage third-party auditors to review compliance with AML/CTF laws, ethical sourcing standards, and other regulatory requirements.

-Reporting and Accountability

Any compliance issues identified during audits will be reported to senior management, and corrective actions will be taken promptly. LAMIE’s compliance officer will be responsible for overseeing all compliance activities.

8. Training and Awareness

-Employee Training

All employees will receive regular training on legal and compliance issues relevant to their roles, including AML/CTF, ethical sourcing, and data protection.

- Ongoing Education

LAMIE will provide ongoing education opportunities to ensure all staff members are up-to-date on the latest legal and compliance requirements.

9. Conclusion

LAMIE’s commitment to legal and regulatory compliance is central to our business operations. By adhering to this framework, we aim to build trust with our customers, suppliers, and regulators, ensuring the long-term success and integrity of our company.