Effective Date: 1/29/2026

Approved By: Owner (A.C. Maher)

1. PURPOSE

It is the policy of A.C. Maher & Co., LLC (“ACM”) to prevent, detect, and report money laundering, terrorist financing, and other illicit financial activities.

This AML Program is established in accordance with:

• The Bank Secrecy Act (BSA)
• The USA PATRIOT Act
• Regulations issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN)
• Dealers in precious metals are classified as “financial institutions” and are therefore required to implement AML programs. 

2. SCOPE

This program applies to:

All employees, officers, and contractors

All customer transactions, including:

• Gold IRA rollovers
• Precious metals purchases and sales
• Custodial transactions
• Wire transfers and funding sources

3. AML PROGRAM REQUIREMENTS

In accordance with federal law, this program includes the four required pillars:

1. Internal policies, procedures, and controls
2. Designation of an AML Compliance Officer
3. Ongoing employee training
4. Independent testing of the program 

4. AML COMPLIANCE OFFICER

The Company designates an AML Compliance Officer (AMLCO) responsible for:

• Day-to-day AML oversight
• Ensuring compliance with BSA/Patriot Act
• Filing reports (e.g., SARs, CTRs where applicable)
• Liaising with regulators and law enforcement
• Updating the AML program

5. RISK-BASED APPROACH

The Company adopts a risk-based AML framework, considering:

• Customer types (retail investors, retirees, entities)
• Transaction size and frequency
• Payment methods (cash, wire, IRA custodians)
• Geographic exposure (domestic vs. foreign)
• Delivery/storage (custodians, depositories)

This aligns with FinCEN guidance requiring programs tailored to business-specific risks. 

6. CUSTOMER IDENTIFICATION PROGRAM (CIP)

The Company will verify the identity of all customers prior to establishing a relationship.

Required Information:

• Full legal name
• Date of birth (individuals)
• Address
• Social Security Number or Tax ID

Verification Methods:

• Government-issued ID
• Third-party identity verification tools
• IRA custodian confirmations

Enhanced Due Diligence (EDD) applies to:

• High-net-worth clients
• Politically Exposed Persons (PEPs)
• Foreign clients
• Unusual transaction behavior

7. KNOW YOUR CUSTOMER (KYC)

The Company will collect and maintain information on:

• Source of funds (especially IRA rollovers)
• Investment objectives
• Expected transaction activity

The Company reserves the right to refuse or terminate relationships where risk cannot be mitigated.

8. TRANSACTION MONITORING

The Company will monitor for suspicious activity, including:

Red Flags:

• Large or structured cash transactions
• Third-party payments
• Customer reluctance to provide information
• Rapid buy/sell activity of metals
• Requests to avoid record keeping
• Unusual IRA rollover patterns

These are consistent with FinCEN-identified indicators of suspicious activity. 

9. SUSPICIOUS ACTIVITY REPORTING (SAR)

The Company will:

• File SARs with FinCEN when suspicious activity is detected
• Maintain strict confidentiality of SAR filings
• Prohibit disclosure (“tipping off”)

10. RECORDKEEPING

The Company will maintain records including:

• Customer identification data
• Transaction records
• Due diligence documentation

Retention period: Minimum 5 years (or longer if required)

11. CASH TRANSACTIONS & STRUCTURING

The Company will:

• Monitor transactions for structuring
• Comply with IRS and BSA reporting thresholds (e.g., Form 8300 where applicable)
• Prohibit assisting customers in evading reporting requirements

12. OFAC COMPLIANCE

The Company will screen all customers against:

• OFAC Sanctions Lists
• Specially Designated Nationals (SDN) List
• Transactions involving sanctioned individuals or countries are prohibited.

13. EMPLOYEE TRAINING

All relevant personnel must receive:

• Initial AML training upon hire
• Annual refresher training
• Training on identifying red flags and reporting procedures

14. INDEPENDENT TESTING

The AML program will be independently reviewed:

• At least annually
• By internal audit or qualified third parties

Testing will evaluate:

• Effectiveness of controls
• Compliance with regulations
• Employee adherence

15. INTERNAL CONTROLS

The Company maintains internal controls including:

• Segregation of duties
• Transaction monitoring systems
• Escalation procedures for suspicious activity
• Documentation and audit trails

16. RESPONSE TO LAW ENFORCEMENT

The Company will:

• Cooperate fully with FinCEN, IRS, and law enforcement
• Respond promptly to subpoenas and requests
• Maintain confidentiality

17. PROGRAM APPROVAL & REVIEW

• This AML Program is approved by senior management
• Reviewed at least annually
• Updated as regulations or business risks change

18. FLORIDA-SPECIFIC CONSIDERATIONS

While AML laws are federal, Florida-based dealers must also:

• Maintain proper business registration
• Comply with consumer protection laws
• Coordinate with state regulators where applicable

19. PENALTIES FOR NON-COMPLIANCE

Failure to comply may result in:

• Civil and criminal penalties
• Regulatory enforcement actions
• Termination of employees involved

20. POLICY STATEMENT

ACM has zero tolerance for money laundering or terrorist financing and is committed to full compliance with all applicable laws.