ML/TF

Money Laundering & Terrorist Financing (ML/TF) Prevention Policy

Purpose

This policy outlines our commitment to preventing money laundering (ML) and terrorist financing

(TF) in accordance with applicable laws and regulations. As a business operating in the precious

metals and jewelry sector, we recognize the importance of maintaining robust measures to mitigate

ML/TF risks.

Scope

This policy applies to all business activities conducted by Baltic Brilliant OÜ, including but not

limited to the sale of jewelry and precious metals through our online platform.

Customer Due Diligence (CDD)

We conduct basic due diligence procedures for all customers engaging in high-value transactions,

including:

– Verifying customer identity when required (e.g., for large or unusual orders).

– Recording relevant customer information for internal records.

Record Keeping

We retain records of transactions, customer communications, and identification data (where

collected) for a minimum period of 5 years.

Monitoring and Reporting

We monitor for suspicious or unusual activity such as:

– Unusually large or irregular orders.

– Transactions involving high-risk countries or individuals.

– Attempts to structure transactions to avoid reporting thresholds.

Suspicious activity will be internally documented and, where required by law, reported to thecompetent financial intelligence unit or authority.

Staff Awareness

All team members are made aware of this policy and understand the importance of compliance with

ML/TF regulations.

Review

This policy is reviewed annually or when there are significant changes in business operations or

regulations.

Contact for Compliance:

info@balticbrilliant.com

+37258868752