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Governance & Integrity

Built on absolute
integrity

Every transaction processed by MAMGIL & FILHO operates within a comprehensive compliance architecture — covering regulatory alignment, counterparty verification, and supply chain integrity.

"Compliance is not a box to be checked — it is the foundation upon which every relationship and every transaction is built. Without it, there is no trust. Without trust, there is no business."

— Marcos Gil, CEO & Founder

Standards we operate by

LBMA

London Bullion Market Association

Full compliance with LBMA responsible gold sourcing guidelines. All precious metal transactions meet Good Delivery standards and supply chain integrity requirements.

Active Compliance
FATF

Financial Action Task Force

All AML procedures are aligned with FATF's 40 Recommendations, including customer due diligence, suspicious transaction reporting, and record-keeping obligations.

Active Compliance
OECD

OECD Due Diligence Guidance

Adherence to OECD guidelines for responsible supply chains in minerals from conflict-affected and high-risk areas — ensuring ethical sourcing at the origin level.

Active Compliance
BACEN / RFB

Brazilian Regulatory Bodies

Full compliance with Banco Central do Brasil (BACEN) foreign exchange regulations and Receita Federal do Brasil (RFB) export and customs requirements.

Active Compliance
KYC / AML

Know Your Customer Protocol

Every partner undergoes identity verification, UBO (Ultimate Beneficial Owner) mapping, source of funds analysis, and sanctions list screening before any engagement.

Active Compliance
Conflict Minerals

Responsible Minerals Sourcing

Commitment to conflict-free sourcing aligned with the Dodd-Frank Act Section 1502 and OECD guidance — no gold from conflict zones enters our supply chain.

Active Compliance

Our policies in detail

01

Code of Ethics and Conduct

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Our Code of Ethics and Conduct establishes the behavioral standards expected of all members of the organization, partners, and agents. We are committed to absolute integrity in all our relationships and transactions — without exception.

We prohibit any form of corruption, bribery, facilitation payments, or irregular conduct. We require full transparency in all dealings, with zero tolerance for practices that deviate from the highest ethical standards of the global market.

  • Zero tolerance for corruption and bribery at any level
  • Mandatory disclosure of conflicts of interest
  • Prohibition of facilitation payments in all jurisdictions
  • Whistleblower protection for good-faith reporting
02

Anti-Money Laundering & KYC Prevention Policy

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We rigorously comply with international Anti-Money Laundering standards. All partners, consultants, mandataries, and financial agents undergo a thorough internal assessment by our Compliance Management team prior to any engagement.

Our KYC process includes Ultimate Beneficial Owner (UBO) identification, source of funds verification, and continuous transaction monitoring aligned with FATF recommendations and OECD guidelines.

  • Identity verification against government-issued documents
  • UBO identification and beneficial ownership mapping
  • OFAC, UN, and EU sanctions list screening
  • Source of funds and source of wealth verification
  • Ongoing transaction monitoring and periodic review
03

Compliance Program & Risk Management

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MAMGIL & FILHO maintains a robust compliance program designed to ensure international regulatory conformity and systematic risk mitigation. Our compliance team conducts ongoing monitoring of all operational processes.

We are fully aligned with LBMA standards for responsible sourcing, ensuring that all gold and precious metal transactions meet the highest benchmarks for supply chain integrity and ethical procurement.

  • Annual compliance program review and update
  • Mandatory compliance training for all personnel
  • Risk-based approach to transaction monitoring
  • Regulatory change tracking across all operating jurisdictions
04

Conflict Minerals & Responsible Sourcing Policy

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MAMGIL & FILHO is committed to ensuring that no gold or precious metals sourced through our operations originate from conflict zones or contribute to human rights violations. Our responsible sourcing policy is aligned with the OECD Due Diligence Guidance and Dodd-Frank Act Section 1502.

We conduct provenance verification on all upstream sourcing, maintain a documented chain of custody from origin to delivery, and require origin declarations from all supply chain participants.

  • Mandatory origin certification for all assets
  • Supply chain audit from mine or vault to delivery
  • Conflict-free minerals declaration required from all suppliers
  • Annual third-party supply chain review

How we vet every partner

No engagement proceeds without clearance

Before any transaction is initiated, every counterparty — buyer, seller, or intermediary — passes through our four-stage vetting process. This is non-negotiable and applies to all engagements regardless of size or urgency.

01
Initial Assessment

Partner identity verified, corporate structure mapped, and UBO (Ultimate Beneficial Owner) identified. PEP status and sanctions exposure assessed.

48h Turnaround
02
Background Investigation

OFAC, UN, EU, and BACEN sanctions screening. Financial history review, adverse media analysis, and regulatory standing verification across jurisdictions.

2–5 Days
03
Documentation Review

Legal entity documentation, operating licenses, and regulatory certificates reviewed. Source of funds and source of wealth verified against stated business profile.

3–7 Days
04
Ongoing Monitoring

Approved partners are subject to continuous transaction monitoring and periodic re-screening. Any material change in risk profile triggers an immediate reassessment.

Continuous

Documentation we provide

KYC Clearance Certificate

A formal certificate confirming that the counterparty has passed our full Know Your Customer verification process — issued to all approved partners.

Chain of Custody Record

A complete documented trail of asset movement from origin to delivery, including all custody transfers, inspection points, and transport records.

Compliance Audit Summary

A summary report of the compliance checks performed on the transaction, available for counterparty review or submission to their own due diligence officers.

LBMA Responsible Sourcing Declaration

Formal declaration confirming that all precious metals in the transaction comply with LBMA responsible gold sourcing guidelines and are conflict-free.

AML Screening Results

Documentation of the AML screening conducted on the transaction parties, including sanctions database results and PEP verification outcomes.

7-Year Documentation Archive

All operational records are retained for a minimum of seven years in a secure, auditable archive — available for regulatory review or legal proceedings if required.

Our Position

"We operate with zero tolerance for corruption, bribery, conflict minerals, and money laundering. Every partner. Every transaction. Every time — without exception."

Zero Corruption Zero Conflict Minerals Zero Money Laundering Zero Tolerance

Questions about our
compliance framework?

Our compliance team is available to provide full documentation and answer any due diligence inquiries from institutional partners and counterparties.

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