Regulatory Compliance & Policies

NexOr Group is committed to full compliance with all applicable AML-CFT laws and regulations, including UAE Federal Decree-Law No. 20 of 2018, Cabinet Decision No. 10 of 2019, and all DMCC Authority compliance directives. The Company adopts a risk-based approach in line with FATF Recommendations.

This policy applies to all employees, contractors, partners, and agents of NexOr Group, and to all transactions involving gold, rough diamonds, and precious metals.

Counterparties and transactions are categorised by risk level:

Low Risk: Established, documented cooperatives with known transaction history. Medium Risk: New counterparties; cross-border transactions above threshold. High Risk: Politically Exposed Persons (PEPs); transactions from FATF high-risk jurisdictions; unusual transaction patterns.

Enhanced Due Diligence (EDD) applies to all High Risk classifications.

Prior to any transaction: identity verification of all counterparties; beneficial ownership verification; source of funds and source of wealth documentation; sanctions screening against UN, EU, US OFAC, and UAE local lists; ongoing monitoring for changes in risk profile.

All transactions monitored for: unusual size, frequency, or pattern relative to customer profile; structuring to avoid reporting thresholds; payments involving elevated-risk jurisdictions. Suspicious transactions are escalated to the Compliance Officer and reported to the UAE FIU via the goAML platform.

All CDD documentation and transaction records are retained for a minimum of five (5) years in accordance with UAE law.

All personnel in customer-facing or transaction roles receive AML-CFT training upon onboarding and annually thereafter.

A designated Compliance Officer is responsible for policy implementation, staff training, suspicious activity reporting, and regulatory liaison.

This policy is reviewed annually and updated to reflect changes in applicable law, FATF guidance, and DMCC directives.

NexOr Group implements supply chain due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRA), Third Edition.

Adopt and communicate this policy to all supply chain partners. Maintain internal structures with clear compliance responsibilities. Retain records of all mineral supply chain transactions for a minimum of 5 years. Integrate due diligence requirements into supplier contracts.

Identify and assess risks against the OECD Annex II model policy: sourcing from conflict-affected and high-risk areas; serious human rights abuses at or near mine sites; support for non-state armed groups; bribery and fraudulent misrepresentation of mineral origin; money laundering; non-payment of taxes and royalties.

Upon identifying risk: report to senior management; consult suppliers on mitigation; implement measurable improvement plans with defined timelines; suspend or terminate relationships where risks cannot be mitigated.

Support independent third-party audit of supply chain due diligence. Engage with recognised audit schemes for ASM contexts. Make audit summaries available to counterparties on request.

Publish an annual Supply Chain Due Diligence Report covering: scope of assessment; risk findings and mitigation actions; progress against prior year commitments; upcoming improvement targets.