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As a company, we are committed to conducting business in accordance with the highest ethical standards. This commitment includes adherence to all applicable laws and regulations aimed at preventing money laundering and terrorist financing. While the majority of transactions on the company website ( involve retail consumers using bank and/or credit cards, this Policy, developed by Brilliant Diamonds (BD), aims to mitigate the risks associated with money laundering and terrorist financing in its business and product sales (both retail and wholesale). The Policy outlines individual responsibilities for compliance with global anti-money laundering and counter-terrorist financing laws ("AML Laws") and ensures that any third parties acting on our behalf also comply.

BD is dedicated to full compliance with all laws. Any employee violating this Policy may face appropriate disciplinary action, including dismissal, and may be subject to personal civil or criminal fines.

For inquiries about this Policy, contact the Administrator of Compliance or your Legal Counsel.

Policy Statement on AML

BD's policy is to comply with all applicable AML Laws globally. We will only conduct business with customers engaged in legitimate activities with funds derived from lawful sources.

This Policy is designed to assist employees, contractors, and third parties acting on the company’s behalf in understanding potential breaches of AML Laws and making informed decisions in line with our corporate position.

Company-wide Endorsement

BD will not penalize management or employees for business losses resulting from adherence to this Policy. Reporting known or suspected breaches of this Policy in good faith to the Administrator or senior management will not result in adverse employment or contract decisions.

Who is subject to this Policy?

This Policy applies globally to BD’s operations, including all legal entities worldwide owned or controlled by BD (including group companies). It extends to directors, officers, employees, contractors, and third parties acting on behalf of the aforementioned.

What is Money Laundering and Terrorist Financing?

Money laundering involves exchanging criminally obtained money or assets for 'clean' money or assets without an obvious link to criminal activity. This also includes money used to fund terrorism. The Policy prohibits activities such as the conversion or transfer of criminal property, conducting financial transactions with criminal property, and the concealment or disguise of criminal property.

Red Flags

Instances that raise suspicions of criminal conduct involving customers, colleagues, or third parties should be reported. Examples of red flags include insufficient or false information from customers, unusual payment methods, and transactions inconsistent with customary business practices.

Compliance Controls

Senior management is responsible for fostering a culture of compliance and implementing effective controls to prevent, detect, and respond to money laundering and terrorist financing. Employees at all levels are obligated to read and follow this Policy, identify red flags, and escalate compliance concerns to the Administrator.

Due Diligence and Record Keeping

Due diligence is conducted at the beginning of any business relationship, and ongoing monitoring is carried out on suppliers, distributors, and other parties. Records of due diligence and ongoing monitoring must be maintained. Non-compliance may result in disciplinary action and checks by Internal Audit.

Non-compliance Consequences

Violations of this Policy may lead to severe civil and/or criminal penalties, including fines, imprisonment, blacklisting, and license revocation. Consequences may also include reputational damage, business restrictions, and the costs associated with investigations.

Updates, Review, and Ownership

This Policy may be updated periodically, with the latest version made available to all employees immediately.