Anti-Money Laundering Program and Policy

General Statement of Purpose

Date: January 30, 2024

It is the policy of MTC OF NY INC., to prohibit the use of our business or services for money laundering and
the finance of terrorism.

This AML Program and Policy has been developed in conformance with the requirements of rules
promulgated by the U.S. Department of Treasury, Financial Crimes Enforcement Network, 31 CFR Chapter
X, Part 1027, under the Bank Secrecy Act as amended by the USA PATRIOT Act of 2001 (Pub.L.107-56)
and is based on MTC OF NY INC., assessment of the money laundering and terrorist financing risks
associated with MTC OF NY INC., transactions pertaining to covered goods.

This Program and Policy will be made available to the U.S. Department of Treasury or any other duly
authorized government agency upon request.

Both this AML Program and Policy and MTC OF NY INC., Risk Assessment have been reviewed and
approved by The Senior Management of MTC OF NY INC., both this Program and the Risk Assessment
may be updated from time to time.

This Program and Policy applies only to the purchase and sale of covered goods defined as precious metals
(of an assay in excess of 500 parts per thousand), precious stones and jewels, and finished goods of which
50% of the value is derived from the precious metals, precious stones or jewels contained in or attached to
such goods.

General Policies

1. It is the policy of MTC OF NY INC., to comply with all cash reporting requirements for receipt of cash in
   a single transaction or in a series of related transactions in an amount of $10,000 or higher. In all such
   cases, an IRS Form 8300 will be completed in full and submitted to the appropriate government agency
2. It is the policy of MTC OF NY INC., periodically to check all known government agency or agency
   sponsored lists of counties that have been found to be non-cooperative in anti-money laundering
   efforts, lists of countries suspected of supporting terrorism and lists of individuals suspected of
   supporting terrorism or engaging in terrorist activity. The purpose of this activity is to determine whether
   any source of supply, distribution channel or individual associated with the business of MTC OF NY
   INC., has been included on such lists. The results will be documented.
3. It is the policy of MTC OF NY INC., to file the relevant IRS form when opening a foreign bank or other
   foreign financial institution account, and, when appropriate, to file the appropriate IRS form pertaining
   to the international transportation of currency or monetary instruments as required by law.
4. It is the policy of MTC OF NY INC., to complete and submit to the appropriate government agencies all
   documents required under state law associated with the purchase of finished goods or other precious
   metals, precious stones, or jewels from members of the public.
5. Any request from a business partner of MTC OF NY INC. to alter its course of dealing with MTC OF NY
   INC., will be the subject of reasonable inquiries designed to determine the reasons for the change in
   course of dealing. Changes in course of dealing can include but are not limited to change in payment
   (receivable or payable) methods or locations, change in delivery methods or locations, introduction of
   heretofore unknown third parties into the course of dealing, change in the chain of distribution.
6. Any request from a business partner of MTC OF NY INC., for an unusual degree of secrecy related to
   the transaction will be the subject of reasonable inquiries designed to determine the reasons for the
   high degree of secrecy
7. It is the policy of MTC OF NY INC., that, when the person or company supplying or purchasing covered
   goods, evades or refuses to respond to reasonable inquiries by MTC OF NY INC., to acquire information
   or explanations required for compliance with the MTC OF NY INC., AML program to:
   • Refer the transaction to the Compliance Officer for assessment.
   • Decide whether or not to engage in the transaction.
8. It is the policy of MTC OF NY INC., to train all relevant employees regarding the laws and regulations
   pertaining to anti-money laundering requirements and the program and policy of MTC OF NY INC.,

Part 1

Identification of Customers and Business Partners

1. It is the policy of MTC OF NY INC., to acquire from all business partners engaged in selling to or
   purchasing covered goods from MTC OF NY INC., and from customers engaged in transactions using
   credit instruments (including credit cards, checks, wire transfers, etc.) standard identifying information.
   This information is to be maintained in written form.
2. All Identification information is corroborated by government issued identification, such as licenses, photo
   identification documents, or passports.
3. It is the policy of MTC OF NY INC., to review all identification information for internal consistency. All
   identification information must be consistent for each supplier or business partner on all identification
   documents, or a reasonable explanation for the inconsistency must be provided.
4. It is the policy of MTC OF NY INC., to complete and submit to the appropriate government agencies all
   documents required under state law associated with the purchase of finished goods or other precious
   metals, precious stones, or jewels from members of the public.

The standard information to be acquired is:

1. Name
2. Address
3. Telephone number
4. Fax number (if any)
5. E-mail address and website.
6. Government issued identification number: (Social Security, tax identification, passport, license, etc.)

1. It is the policy of MTC OF NY INC., to acquire the above-mentioned identification information for any third
   party associated in any manner with any transaction for covered goods in which MTC OF NY INC., is
   engaged, including third party payers or payees, recipients, suppliers, or senders of goods
2. It is the policy of MTC OF NY INC., to acquire all required identification information from members of the
   public, foreign sources of supply or other non-dealers from whom we purchase or acquire precious
   metals, precious stones, jewels or finished goods, 50% of the value of which is comprised of the precious
   metals, precious stones or jewels contained in or attached to such goods.
3. It is the policy of MTC OF NY INC., to periodically check all government agency or agency sponsored
   lists of persons suspected of engaging in criminal activity or countries that support terrorism or have
   been identified as non-cooperative in efforts to combat money laundering. It is the responsibility of the
   Compliance Officer to review the transactions and business partners of MTC OF NY INC., to determine
   if any of the countries, individuals or entities are engaged in business or any transactions with MTC OF
   NY INC.
4. In cases where any party to a transaction evades or refuses to respond to reasonable inquiries designed
   to identify the person or otherwise comply with the AML Program of MTC OF NY INC., it is the policy of
   MTC OF NY INC., to:
   • Refer the transaction to the Compliance Officer for assessment.
   • Decide whether or not to engage in the transaction.

Part 2

Monitoring Business Transactions

A. Purchases of covered goods from members of the public

1. Purchases of covered goods by MTC OF NY INC., from members of the public which result in
   monetary payment to the party offering the covered goods require identification of the party offering
   the item consistent with MTC OF NY INC., ’s identification policy as described above.
2. Compliance with state laws applicable to such purchases is required.
3. MTC OF NY INC., makes payments for such purchases only in the form of:
   • A company checks.
   • Wire transfer
4. All such purchases and payments are made only directly to the person offering the covered goods
   for sale, not to a third party, unless such third party has been fully identified and the reason for the
   participation of the third party adequately explained.
5. In cases where any party to a transaction evades or refuses to respond to reasonable inquiries
   designed to identify the person, it is the policy of MTC OF NY INC., to:
   • Refer the transaction to the Compliance Officer for assessment.
   • Decide whether or not to engage in the transaction.

Purchases or sales of covered goods to or from foreign sources of supply or other non-dealers (estate
sales, US government-sponsored sales, bankruptcy trustees, auction houses, etc.)

1. All transactions involving purchases or sales to or from foreign sources of supply or other non-dealers require identification procedures as described above.
2. Payments for all such purchases of covered goods are in the form of:
   • company check.
   • Wire transfer
3. It is the policy of MTC OF NY INC., to inquire of all foreign-based sources of supply about the
   implementation of an AML program consistent with their local laws. If the foreign source of supply
   is implementing an AML program, this communication is provided to MTC OF NY INC., in writing.
4. In cases where any party to a transaction evades or refuses to respond to reasonable inquiries
   designed to monitor the transaction or otherwise comply with MTC OF NY INC., ’s AML program,
   it is the policy of MTC OF NY INC., to:
   • Refer the transaction to the Compliance Officer for assessment.
   • Decide whether or not to engage in the transaction.
5. Any request from a business partner to alter its course of dealing regarding transactions with MTC
   OF NY INC., will be the subject of reasonable inquiries designed to determine the reasons for the
   change in the course of dealings. Changes in course of dealing include but are not limited to change
   in payment (receivable or payable) methods or locations, change in delivery methods or locations,
   introduction of heretofore unknown third parties into the course of dealing, change in the chain of
   distribution.
6. In cases where any party to a transaction evades or refuses to respond to reasonable inquiries
   regarding changes in course of dealing with MTC OF NY INC., it is the policy of MTC OF NY
   INC., to:
   • Refer the transaction to the Compliance Officer for assessment.
   • Decide whether or not to engage in the transaction.

Part 3

Detecting and Responding To “Red Flags

1. It is the policy of MTC OF NY INC., to detect and respond to red flags that might raise suspicion that a
   particular transaction or business partner or customer is engaging in activity designed to facilitate
   money laundering or terrorist financing.
2. When “red flags” are detected, it is the policy of MTC OF NY INC., to
   • Refer the transaction to the Compliance Officer for assessment.

The following general categories describe “red flags” which trigger the above referenced procedure:

Unusual payment methods

Unusual payment methods include but are not limited to

1. Use of large quantities of cash
2. Sequentially numbered money orders
3. Travelers check in large quantities.
4. Repeated use of cashier’s checks
5. Payments from third parties
6. Any combination of the above

Unwillingness by a customer, business partner or supplier to supply complete or accurate identification
information.

1. A business partner or customer evades or refuses to supply identification information.
2. A business partner or customer evades or refuses to answer reasonable inquiries about a
   transaction.
3. A business partner or customer requests an unusual degree of secrecy related to a
   transaction.
4. A business partner or customer uses a fake identification document.

Unusual purchases

Activities under this category include but are not limited to:

1. Change of delivery methods
2. Change of payment methods
3. Requests for payment or delivery to a third party
4. Change of banking reference
5. Change in order quantities (usually sudden increase)
6. Change in frequency of transactions.
7. Repeated purchase and return of items or orders.
8. Increased trade-in or return activity.
9. Change in the goods supplied (either quantity or type of goods)

Purchases or sales that are not in conformity with standard industry practices.

Activities under this category include but are not limited to:

1. Requests for payments not to be recorded in the books and records of the company.
2. Requests that goods not be entered into inventory records.
3. Requests for unusual activity, such as melting precious metals.
4. Unusual quantities of goods ordered.
5. Requests for products not usually offered by a supplier company
6. Requests for an unusual degree of secrecy

Part 4

Procedures for Responding to Treasury and Requests for AML Information

Requests for Information from Duly Authorized Government Agencies

1. It is the policy of MTC OF NY INC. to refer all requests from the Treasury or any other duly authorized
   government agency to the Compliance Officer for response.
2. It is the policy of MTC OF NY INC., to refer all requests from Treasury or any other duly authorized
   government agency to MTC OF NY INC., legal counsel for response.
3. All requests for information from Treasury or other duly authorized government agencies will be
   reviewed by the responsible employee within two to four weeks of the original request from the
   government agency, or in conformance with the timetable provided by the government agency.
4. All responses to government agencies will be prepared in written form by the Legal Counsel and
   reviewed prior to submission by Compliance Officer of MTC OF NY INC.

Voluntary Reporting of Suspicious Activity

It is the policy of MTC OF NY INC., to file Suspicious Activity Reports (“SAR”) with the appropriate
government agency when appropriate. Any employee may suggest to the Compliance Officer the filing of
a SAR. It is the determination of the CO whether or not to file a SAR.

Suspicious activity is defined as any activity conducted or an attempt to conduct an activity that an
employee of MTC OF NY INC., suspects or has reason to believe involves money from criminal activity, is
designed to evade this AML Program and Policy or any provision of the AML regulations pursuant to the
USA PATRIOT Act, appears to serve no legitimate business purpose and for which no available facts
provide reasonable explanation.

When such activity is detected, the CO will review the activity and determine whether or not to recommend
the filing of a SAR. Legal Counsel of MTC OF NY INC., will review such determination.

All SARs will be filed using the Bank Secrecy Act’s online e-Filing system. A record of SARs filed according
to the provisions of MTC OF NY INC., ’s AML Policy and Program will be maintained with all other
documents and records for AML compliance.

Part 5

Documentation and Records of AML Compliance

It is the policy of MTC OF NY INC., to document all compliance actions in connection with this program and
policy.

It is the policy of MTC OF NY INC., to maintain the records and documents associated with compliance
with this AML Program and Policy for a period of five years. These records are to be maintained separately
from the books and records of MTC OF NY INC.

It is the policy of MTC OF NY INC., to ensure the security of the records of AML Compliance.

This document is the AML Compliance Program and Policy of MTC OF NY INC. It has been endorsed and
supported by the senior management of MTC OF NY INC., it will be updated and amended as needed.

1701 SUMMIT AVENUE, UNION CITY, NJ 07087 UNITES STATES
212-502-1899