{"id":6678,"date":"2026-07-14T12:05:07","date_gmt":"2026-07-14T12:05:07","guid":{"rendered":"https:\/\/demo.realmoneyeu.com\/terms-and-conditions\/"},"modified":"2026-08-25T09:38:04","modified_gmt":"2026-08-25T09:38:04","slug":"terms-and-conditions","status":"publish","type":"page","link":"https:\/\/demo.realmoneyeu.com\/en\/terms-and-conditions\/","title":{"rendered":"Terms and Conditions"},"content":{"rendered":"\t\t
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WEBSITE TERMS AND CONDITIONS OF USE<\/h1>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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HOLDER OF THE METAL BANK<\/u><\/strong><\/strong><\/p>\n

    \n
  • The provider of the LBMA physical gold sales service that offers THE REAL MONEY’s clients services and products related to physical gold is Real Money Europe Limited LTD <\/u><\/strong>Registration number 813181, Block 4 Harcourt Centre, Harcourt Road, Dublin 2, D02 HW77, Dublin, Ireland. Physical gold METAL BANK. Every product and activity relating to the sale, purchase, supply, custody and advisory services on LBMA gold is managed by Real Money Europe, subject to Irish law. All references on the REALMONEYEU.COM platform relating to LBMA physical gold refer to products and Services provided by Real Money Europe Ltd. Hereinafter, also the METAL BANK.<\/li>\n
  • The METAL BANK oversees the deposits opened by clients for the custody of the physical gold they have purchased.<\/li>\n<\/ul>\n
      \n
    • The deposit plans may offer different options and vary in terms of volume, activation cost, custody cost, insurance costs, management costs, etc. The METAL BANK may, at its discretion, modify, remove, suspend or create deposit plans and the general terms and conditions associated with them.<\/li>\n<\/ul>\n
        \n
      • The custody of the gold purchased by clients is managed by the METAL BANK at its discretion, including through the use of external maximum-security LBMA vaults, taking into account logistics and pricing or more favourable services, without thereby limiting the maximum possible guarantee and security for the protection of the client.<\/li>\n<\/ul>\n
          \n
        1. SERVICES AND CUSTODY PLANS<\/u><\/strong><\/strong><\/li>\n<\/ol>\n

          The METAL BANK offers various services as indicated below:<\/p>\n

            \n
          • Purchase of LBMA physical gold<\/li>\n
          • Delivery of purchased gold to the client’s home address<\/li>\n
          • Custody of purchased gold in maximum-security vaults<\/li>\n
          • Management of the purchase and sale processes for gold held in custody<\/li>\n
          • Administration of the deposit plan on behalf of the Ultimate Beneficial Owner<\/li>\n
          • Issuance of deposit ownership certificates<\/li>\n
          • Issuance of digital blockchain certificates of the deposit’s valuation with a certified date<\/li>\n
          • Creation of bars in different formats<\/li>\n
          • Customised custody services (in-out, premium plus, stability, future, relax, etc.)<\/li>\n
          • Purchase price protection<\/li>\n<\/ul>\n
              \n
            1. ONBOARDING PROCESS AND AML OBLIGATIONS<\/u><\/strong><\/strong><\/li>\n<\/ol>\n\n\n\n
               <\/td>\n\n

              Anti-Money Laundering<\/strong><\/p>\n

              European AML regulation<\/p>\n<\/td>\n

              		\n

              KYC \/ KYB<\/strong><\/p>\n

              Verification<\/strong><\/p>\n

              Natural and legal persons<\/p>\n<\/td>\n

              		\n

              Risk-Based<\/strong><\/p>\n

              Approach<\/strong><\/p>\n

              Proportional to risk<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
              \n

              3.1<\/strong><\/p>\n<\/td>\n

              		\n

              WHY WE ARE SUBJECT TO AML REGULATIONS<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

              The METAL BANK (hereinafter “METAL BANK” or “the Company”) is committed to combating money laundering (AML \u2014 Anti-Money Laundering) and terrorist financing (CFT \u2014 Combating the Financing of Terrorism). This is a fundamental commitment, not merely a regulatory obligation.<\/p>\n

              We believe that a healthy and transparent precious metals market requires responsible operators who adopt high standards of customer due diligence. This Policy transparently describes our approach to preventing financial crime, the procedures we adopt to verify customer identity, and the criteria we use to assess the risk associated with each business relationship.<\/p>\n\n\n\n
              \n

              Our commitment: the METAL BANK ensures that its activities of buying, selling and safekeeping physical gold, including through qualified depositaries, are carried out in full compliance with applicable regulations and are not used for unlawful activities, in order to protect our clients and the integrity of the gold market.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
              \n

              3.2<\/strong><\/p>\n<\/td>\n

              		\n

              REGULATORY REFERENCES<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

              This Policy has been drafted in accordance with the following regulatory framework:<\/p>\n\n\n\n\n\n\n\n
              \n

              Regulation<\/strong><\/p>\n<\/td>\n

              		\n

              Description<\/strong><\/p>\n<\/td>\n<\/tr>\n

              \n

              EU Reg. 2024\/1624 (AMLR)<\/strong><\/p>\n<\/td>\n

              		\n

              New European regulatory framework on anti-money laundering, which will introduce harmonised rules at EU level, with phased application starting in 2027<\/p>\n<\/td>\n<\/tr>\n

              \n

              GDPR \u2014 EU Reg. 2016\/679<\/strong><\/p>\n<\/td>\n

              		\n

              Protection of personal data \u2014 legal basis for the processing of KYC\/KYB data<\/p>\n<\/td>\n<\/tr>\n

              \n

              FIU Communications<\/strong><\/p>\n<\/td>\n

              		\n

              Anomaly indicators for suspicious transactions in the precious metals and investment gold sector<\/p>\n<\/td>\n<\/tr>\n

              \n

              FATF Standards (2021+2024)<\/strong><\/p>\n<\/td>\n

              		\n

              International recommendations on the risk-based approach for METAL BANK \u2014 methodological reference<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
              \n

              3.3<\/strong><\/p>\n<\/td>\n

              		\n

              GLOSSARY<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

              Below are the main definitions and acronyms used in this Policy:<\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
              \n

              Acronym<\/strong><\/p>\n<\/td>\n

              		\n

              Term<\/strong><\/p>\n<\/td>\n

              		\n

              Definition<\/strong><\/p>\n<\/td>\n<\/tr>\n

              \n

              AML<\/strong><\/p>\n<\/td>\n

              		\n

              Anti-Money Laundering<\/strong><\/p>\n<\/td>\n

              		\n

              Anti-money laundering: the set of measures aimed at preventing and combating the laundering of proceeds from unlawful activities<\/p>\n<\/td>\n<\/tr>\n

              \n

              CFT<\/strong><\/p>\n<\/td>\n

              		\n

              Combating the Financing of Terrorism<\/strong><\/p>\n<\/td>\n

              		\n

              Combating the financing of terrorism<\/p>\n<\/td>\n<\/tr>\n

              \n

              ML\/TF<\/strong><\/p>\n<\/td>\n

              		\n

              Money Laundering \/ Terrorist Financing<\/strong><\/p>\n<\/td>\n

              		\n

              Money laundering and terrorist financing: the two main risks that AML\/CFT procedures aim to prevent<\/p>\n<\/td>\n<\/tr>\n

              \n

              KYC<\/strong><\/p>\n<\/td>\n

              		\n

              Know Your Customer<\/strong><\/p>\n<\/td>\n

              		\n

              Verification of the identity of an individual client: collection and verification of identification data, documentation and the source of funds<\/p>\n<\/td>\n<\/tr>\n

              \n

              KYB<\/strong><\/p>\n<\/td>\n

              		\n

              Know Your Business<\/strong><\/p>\n<\/td>\n

              		\n

              In-depth verification of a corporate client: collection and verification of corporate data, directors and the ultimate beneficial owner<\/p>\n<\/td>\n<\/tr>\n

              \n

              CDD<\/strong><\/p>\n<\/td>\n

              		\n

              Customer Due Diligence<\/strong><\/p>\n<\/td>\n

              		\n

              Customer due diligence: standard procedure applied to all clients<\/p>\n<\/td>\n<\/tr>\n

              \n

              EDD<\/strong><\/p>\n<\/td>\n

              		\n

              Enhanced Due Diligence<\/strong><\/p>\n<\/td>\n

              		\n

              Enhanced due diligence: in-depth procedure for high-risk clients<\/p>\n<\/td>\n<\/tr>\n

              \n

              SDD<\/strong><\/p>\n<\/td>\n

              		\n

              Simplified Due Diligence<\/strong><\/p>\n<\/td>\n

              		\n

              Simplified due diligence: streamlined procedure for clients with documented low risk<\/p>\n<\/td>\n<\/tr>\n

              \n

              PEP<\/strong><\/p>\n<\/td>\n

              		\n

              Politically Exposed Person<\/strong><\/p>\n<\/td>\n

              		\n

              Politically Exposed Person: an individual who holds or has held prominent public functions<\/p>\n<\/td>\n<\/tr>\n

              \n

              UBO<\/strong><\/p>\n<\/td>\n

              		\n

              Ultimate Beneficial Owner<\/strong><\/p>\n<\/td>\n

              		\n

              Ultimate Beneficial Owner: the natural person who owns or controls a legal entity (holding > 25%)<\/p>\n<\/td>\n<\/tr>\n

              \n

              AMLCO<\/strong><\/p>\n<\/td>\n

              		\n

              AML Compliance Officer<\/strong><\/p>\n<\/td>\n

              		\n

              AML Compliance Officer: oversight of AML\/CFT procedures<\/p>\n<\/td>\n<\/tr>\n

              \n

              FIU<\/strong><\/p>\n<\/td>\n

              		\n

              Financial Intelligence Unit<\/strong><\/p>\n<\/td>\n

              		\n

              Authority that receives Suspicious Transaction Reports (STRs)<\/p>\n<\/td>\n<\/tr>\n

              \n

              SOS<\/strong><\/p>\n<\/td>\n

              		\n

              Suspicious Transaction Report<\/strong><\/p>\n<\/td>\n

              		\n

              Communication sent to the UIF when an ML\/TF transaction is suspected<\/p>\n<\/td>\n<\/tr>\n

              \n

              LBMA<\/strong><\/p>\n<\/td>\n

              		\n

              London Bullion Market Association<\/strong><\/p>\n<\/td>\n

              		\n

              International association that certifies gold and silver refineries \u2014 reference standard for the custody of metals<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
              \n

              3.4<\/strong><\/p>\n<\/td>\n

              		\n

              WHY WE VERIFY YOUR IDENTITY<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

              Identity verification is not merely a legal obligation: it is the primary tool through which the METAL BANK protects its clients and safeguards the integrity of the physical gold market. The main risk for a METAL BANK is being unintentionally involved in unlawful activities.<\/p>\n\n\n\n
              \n

              These controls protect both the METAL BANK and \u2014 above all \u2014 our clients, ensuring a safe and reliable environment for investing in physical gold.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
              \n

              3.5<\/strong><\/p>\n<\/td>\n

              		\n

              OUR APPROACH: RISK-BASED AND HUMAN-FIRST<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

              The Company adopts a risk-based approach (RBA), in accordance with the FATF Recommendations for METAL BANKs (updated to 2024) and applicable supervisory provisions. This means that:<\/p>\n

                \n
              • We do not treat all clients in the same way: those presenting higher-risk characteristics are subject to more in-depth checks;<\/li>\n
              • Those with a documented low-risk profile may access services through streamlined procedures;<\/li>\n
              • Compliance resources are concentrated where risk is greatest, without unnecessarily burdening the experience of low-risk clients.<\/li>\n<\/ul>\n

                Our approach combines face-to-face identification \u2014 carried out by our staff \u2014 with in-depth documentary verification. This dual level of control ensures high standards for all clients. Clients are classified into three risk categories \u2014 LOW, MEDIUM, HIGH \u2014 based on factors such as country of residence, type of transactions, and any PEP or sanctioned-person status. The level of verification required is proportionate to the assigned risk category.<\/p>\n\n\n\n
                \n

                3.6<\/strong><\/p>\n<\/td>\n

                		\n

                HOW WE VERIFY YOUR IDENTITY<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                3.6.1  The KYC Process for Individuals<\/strong><\/p>\n

                The identity verification process (KYC) for individual clients always involves direct, in-person contact between the client and the Company. It is not possible to complete the KYC process automatically or without human interaction.<\/p>\n\n\n\n
                \n

                The client attends in person at the METAL BANK’s operating office or meets with an authorised METAL BANK advisor. In this context, the following documentation is collected:<\/p>\n

                a)  <\/strong>Valid identity document (ID card, passport, driving licence);<\/p>\n

                b)  <\/strong>Italian Tax Code (Codice Fiscale) or foreign equivalent;<\/p>\n

                c)  <\/strong>Document evidencing ownership of a bank account held in the client’s name (for wire transfers);<\/p>\n

                d)  <\/strong>Proof of residence (recent utility bill or bank statement, no older than 3 months);<\/p>\n

                e)  <\/strong>Occupation and employer;<\/p>\n

                f)  <\/strong>Declaration of any PEP status;<\/p>\n

                g)  <\/strong>Documentation on the source of funds used to purchase the gold (employment income, business income, inheritance, sale of assets, existing liquidity \u2014 with supporting documentation).<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                3.6.2  Purpose and Nature of the Business Relationship<\/strong><\/p>\n

                During the identity verification process, the METAL BANK collects information directly from the client to understand the purpose and nature of the business relationship. This information includes, by way of example:<\/p>\n

                  \n
                • Type of transactions expected (spot purchases, instalment plans, partial sales);<\/li>\n
                • Source of the funds used to purchase the gold;<\/li>\n
                • Experience and general knowledge of precious metals investments.<\/li>\n<\/ul>\n

                  This information is always collected through direct, in-person interaction with the client, and serves to ensure an adequate risk assessment proportionate to the client’s profile, in compliance with AML\/KYC\/KYB regulations.<\/p>\n

                  3.6.3  The KYB Process for Legal Entities<\/strong><\/p>\n

                  For corporate clients \u2014 companies, firms, foundations, trusts \u2014 the verification process (KYB) requires additional documentation beyond individual KYC:<\/p>\n

                    \n
                  1. a) <\/strong>Copy of the up-to-date articles of association and memorandum of incorporation;<\/li>\n
                  2. b) <\/strong>LEI code, if available;<\/li>\n
                  3. c) <\/strong>Certificate of incorporation\/company registry extract or equivalent document (no older than 3 months);<\/li>\n
                  4. d) <\/strong>Latest approved financial statements;<\/li>\n
                  5. e) <\/strong>Identity documents of directors and shareholders\/members holding more than 25%;<\/li>\n
                  6. f) <\/strong>Complete ownership structure and identification of the ultimate beneficial owners (UBOs);<\/li>\n
                  7. g) <\/strong>Copy of the VAT registration certificate;<\/li>\n
                  8. h) <\/strong>Business sector and rationale for the investment in physical gold.<\/li>\n<\/ol>\n\n\n\n
                    \n

                    Please note \u2014 <\/strong>In the absence of sufficient information to identify the Ultimate Beneficial Owner (UBO), the METAL BANK will not proceed with establishing the business relationship.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                    3.6.3.1  Identification of the Ultimate Beneficial Owner (UBO)<\/strong><\/p>\n

                    The METAL BANK identifies the Ultimate Beneficial Owner according to the following criteria:<\/p>\n

                      \n
                    • For legal entities: the natural person who directly or indirectly owns or controls more than 25% of the capital or voting rights, or who otherwise exercises control over management. In the absence of any such identifiable persons, the ultimate beneficial owner is the legal representative;<\/li>\n
                    • For trusts and similar legal arrangements: the settlor, the trustee, the protector, and the beneficiaries or class of beneficiaries.<\/li>\n<\/ul>\n

                      For each Ultimate Beneficial Owner identified, the Company obtains a declaration signed by the legal representative, verifies their identity using the same criteria applied to individuals, and carries out screening against PEP and international sanctions lists.<\/p>\n

                      3.6.4  Absolute Prohibition on Anonymous Relationships<\/strong><\/p>\n\n\n\n
                      \n

                      Absolute prohibition \u2014 the <\/strong>METAL BANK does not establish or maintain business relationships with anonymous clients, clients using a fictitious identity, clients who refuse to provide the information necessary for verification, or clients who provide false or contradictory information. Where verification cannot be completed, the METAL BANK will refuse to establish the relationship and will assess whether grounds exist for a Suspicious Transaction Report (STR) to the UIF.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
                      \n

                      3.7<\/strong><\/p>\n<\/td>\n

                      		\n

                      HOW WE ASSESS EACH CLIENT’S RISK<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                      Each client undergoes a risk assessment at the time of onboarding and periodically throughout the business relationship. The assessment takes into account the following main factors, in accordance with the FATF Recommendations and the applicable Irish AML\/CFT provisions:<\/p>\n\n\n\n\n\n\n\n
                      \n

                      Category<\/strong><\/p>\n<\/td>\n

                      		\n

                      Risk factors analysed<\/strong><\/p>\n<\/td>\n<\/tr>\n

                      \n

                      Client-related factors<\/strong><\/p>\n<\/td>\n

                      		\n

                      Residence\/domicile; nationality; type (individual, company, foundation, trust); any PEP status; previous reports or business relationships; consistency between the declared profile and the transactions carried out<\/p>\n<\/td>\n<\/tr>\n

                      \n

                      Geographic factors<\/strong><\/p>\n<\/td>\n

                      		\n

                      Country of residence\/domicile; countries of origin of funds; countries classified as high-risk by the FATF (grey\/black list); countries subject to EU, UN or OFAC sanctions<\/p>\n<\/td>\n<\/tr>\n

                      \n

                      Operational factors<\/strong><\/p>\n<\/td>\n

                      		\n

                      Amount and frequency of transactions; consistency with declared income and assets; source of funds; type of plan (instalment vs. spot); anomalous variations from the initial profile<\/p>\n<\/td>\n<\/tr>\n

                      \n

                      Factors related to the products and services offered<\/strong><\/p>\n<\/td>\n

                      		\n

                      Origin of the gold contributed; LBMA certifications of the custodian refineries; any gold of unknown or uncertified origin; requests to convert large amounts into cash<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
                      \n

                      3.8<\/strong><\/p>\n<\/td>\n

                      		\n

                      CUSTOMER VERIFICATION<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                      Based on the risk assessment, each client is assigned a proportionate level of verification:<\/p>\n\n\n\n\n\n
                      \n

                      Level<\/strong><\/p>\n<\/td>\n

                      		\n

                      When it applies<\/strong><\/p>\n<\/td>\n

                      		\n

                      What it involves<\/strong><\/p>\n<\/td>\n<\/tr>\n

                      \n

                      Standard CDD<\/strong><\/p>\n<\/td>\n

                      		\n

                      Clients with a medium\/low risk profile<\/p>\n<\/td>\n

                      		\n

                      Full identity verification (KYC\/KYB), understanding of the purpose of the relationship, periodic monitoring<\/p>\n<\/td>\n<\/tr>\n

                      \n

                      Enhanced EDD<\/strong><\/p>\n<\/td>\n

                      		\n

                      High-risk clients<\/p>\n<\/td>\n

                      		\n

                      In-depth verification of the source of funds and wealth, senior management approval, continuous and intensive monitoring<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
                      \n

                      3.9<\/strong><\/p>\n<\/td>\n

                      		\n

                      POLITICALLY EXPOSED PERSONS (PEP)<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                      Under the law, a Politically Exposed Person (PEP) is a natural person who holds or has held prominent public functions. Examples include, on a non-exhaustive basis:<\/p>\n

                        \n
                      • Heads of State and Government; Ministers and Deputy Ministers<\/li>\n
                      • Members of parliament and legislative assemblies<\/li>\n
                      • Members of the governing bodies of political parties<\/li>\n
                      • Members of Supreme Courts, Constitutional Courts and other high-level judicial bodies<\/li>\n
                      • Ambassadors, charg\u00e9s d’affaires and high-ranking military officers<\/li>\n
                      • Members of the management bodies of state-owned enterprises<\/li>\n
                      • Close family members and persons known to be closely associated with the individuals listed above<\/li>\n<\/ul>\n

                        While acknowledging the possibility of establishing relationships with PEPs under applicable law, the METAL BANK adopts a prudential policy which, in most cases, provides for the refusal or termination of the relationship, unless otherwise justified by a reasoned assessment of the Compliance Officer.<\/p>\n\n\n\n
                        \n

                        3.10<\/strong><\/p>\n<\/td>\n

                        		\n

                        GEOGRAPHIC RESTRICTIONS<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                        The METAL BANK does not accept the onboarding of clients who are resident, domiciled, or nationals of countries subject to international restrictive measures imposed by the United States, the European Union or the United Nations, nor clients appearing on OFAC sanctions lists.<\/p>\n\n\n\n
                        \n

                        Excluded countries (examples) \u2014 <\/strong>By way of example and on a non-exhaustive basis, this category currently includes: Cuba, Iran, North Korea, Syria, Russia (sanctioned persons), as well as any other country subject to equivalent sanctions regimes imposed by the competent international authorities.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                        For clients resident in countries included on the FATF grey list or in high-risk countries, the METAL BANK applies enhanced due diligence measures (EDD). The establishment of the business relationship is subject to the assessment of the Compliance Officer.<\/p>\n

                        The lists of high-risk and sanctioned countries are consulted and updated based on the official publications of:<\/p>\n

                          \n
                        • FATF \u2014 Financial Action Task Force (grey and black lists);<\/li>\n
                        • European Union \u2014 European Council Regulations on sanctions;<\/li>\n
                        • United Nations \u2014 Security Council Resolutions (UNSCR);<\/li>\n
                        • OFAC \u2014 Office of Foreign Assets Control (SDN List and Blocked Persons List);<\/li>\n
                        • UIF \u2014 Communications from the Financial Intelligence Unit for Ireland.<\/li>\n<\/ul>\n\n\n\n
                          \n

                          3.11<\/strong><\/p>\n<\/td>\n

                          		\n

                          PERIODIC UPDATE OF THE CLIENT PROFILE<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                          Identity verification does not end at onboarding. During the course of the business relationship, the METAL BANK may request the updating of client data and documents in the following circumstances:<\/p>\n

                            \n
                          • Expiry of the identity documents provided;<\/li>\n
                          • Significant change in the operational profile (e.g. a substantial increase in the amounts invested);<\/li>\n
                          • Changes in the ownership structure, for corporate clients;<\/li>\n
                          • Regulatory updates requiring the collection of new information;<\/li>\n
                          • Reports of anomalies or unusual transactions relative to the declared profile.<\/li>\n<\/ul>\n\n\n\n
                            \n

                            In such cases, the METAL BANK may temporarily suspend access to certain services until the verification update has been completed. The client is always informed in advance and in a transparent manner of the information requested and the reasons for the request.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
                            \n

                            3.12<\/strong><\/p>\n<\/td>\n

                            		\n

                            SUSPICIOUS TRANSACTIONS AND REPORTING OBLIGATIONS<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                            The Company is required by law to report to the UIF any transactions which it suspects, or has reasonable grounds to suspect, involve money laundering or terrorist financing.<\/p>\n\n\n\n
                            \n

                            Confidentiality obligation (Tipping Off)<\/strong><\/p>\n

                            In the event of a report, it is absolutely prohibited to inform the client of its existence (confidentiality obligation \u2014 tipping off). Accordingly, should the METAL BANK proceed with a report concerning a client, it will not be able to disclose this to the client.<\/p>\n

                            The submission of an STR to the UIF does not in itself constitute an accusation against the client. The assessment is carried out by the competent authorities.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
                            \n

                            3.13<\/strong><\/p>\n<\/td>\n

                            		\n

                            YOUR RIGHTS<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                            In connection with the AML\/KYC\/KYB procedures, clients may have questions about the data collected and how it is used. For any information, please contact the METAL BANK’s Compliance Officer. Please note, however, that:<\/p>\n\n\n\n\n\n\n\n
                            \n

                            GDPR right<\/strong><\/p>\n<\/td>\n

                            		\n

                            Applicability in the AML context<\/strong><\/p>\n<\/td>\n<\/tr>\n

                            \n

                            Right to erasure (Art. 17 GDPR)<\/strong><\/p>\n<\/td>\n

                            		\n

                            NOT exercisable for data processed in fulfilment of AML obligations, must be retained for at least 5 years from the termination of the relationship (Section 55 of the Criminal Justice (Money Laundering and Terrorist Financing) (Act 2010, as amended).<\/p>\n<\/td>\n<\/tr>\n

                            \n

                            Right to object to processing (Art. 21 GDPR)<\/strong><\/p>\n<\/td>\n

                            		\n

                            NOT applicable to processing based on a legal obligation (KYC\/KYB\/AML).<\/p>\n<\/td>\n<\/tr>\n

                            \n

                            Right of access, rectification and portability (Arts. 15-20 GDPR)<\/strong><\/p>\n<\/td>\n

                            		\n

                            Exercisable within the limits of AML regulations. Contact: privacy@realmoneyeu.com<\/a><\/p>\n<\/td>\n<\/tr>\n

                            \n

                            Complaint to the Supervisory Authority<\/strong><\/p>\n<\/td>\n

                            		\n

                            Always available: the Data Protection Authority<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n
                            \n

                            Compliance \/ privacy contact<\/strong><\/p>\n<\/td>\n

                            		\n

                            compliance@realmoneyeu.com<\/p>\n<\/td>\n<\/tr>\n

                            \n

                            Website<\/strong><\/p>\n<\/td>\n

                            		\n

                            demo.realmoneyeu.com \u2014 Privacy section<\/p>\n<\/td>\n<\/tr>\n

                            \n

                            Registered office<\/strong><\/p>\n<\/td>\n

                            		\n

                            METAL BANK \u2014 Block 4 Harcourt Centre, Harcourt Road, Dublin 2, D02 HW77, Dublin, Ireland<\/p>\n<\/td>\n<\/tr>\n

                            \n

                            Data Protection Authority (complaints)<\/strong><\/p>\n<\/td>\n

                            		\n

                            Complaints section of the website<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                              \n
                            1. GOLD PURCHASE PROCEDURES<\/strong><\/li>\n<\/ol>\n

                              The purchase of gold takes place only after positive confirmation of the onboarding process.<\/p>\n

                              At the end of the onboarding process, access to the client’s private area is confirmed, allowing them to begin managing the functions available on the Platform, including:<\/p>\n

                                \n
                              • Purchase<\/li>\n
                              • Sale<\/li>\n
                              • Custody<\/li>\n<\/ul>\n

                                Access to the private area is granted starting with a membership that involves no cost to the client. LIBERTY is the membership that allows the client to begin operating with the basic functions of physical gold purchase and custody plans.<\/p>\n

                                Purchases are made through the client’s own account.<\/p>\n

                                IMPORTANT<\/u><\/strong>: given that the purchase only takes place once we are in possession of your funds in our bank accounts, when you start the purchase process you will be shown an indicative public price. This indicative price may not be the final public price at the actual time of purchase, as the value of the metal is subject to constant fluctuation. For this reason, please note that the price shown at the start of the purchase process may vary upward or downward, thereby changing the actual weight of the metal purchased.<\/p>\n

                                  \n
                                • Public purchase price<\/strong><\/li>\n<\/ul>\n

                                  The “PUBLIC PRICE” is the price set by the METAL BANK by applying an additional amount to the London fixing price, which may vary depending on market trends and the strategies adopted by the bank itself.<\/p>\n

                                  It should therefore be borne in mind that the price shown in the London fixing does not correspond to the “PUBLIC PRICE” displayed by the METAL BANK at the time of the Client’s purchase.<\/p>\n

                                    \n
                                  • Indicative selling price<\/strong><\/li>\n<\/ul>\n

                                    The public selling price is subject to fluctuation. For this reason, the public selling price that has not yet been fixed as executed is referred to as the “INDICATIVE SELLING PRICE”. This parameter, shown during the purchase stages, is to be regarded as indicative until the process is actually concluded by the METAL BANK, and cannot be modified until the purchase process is completed.<\/p>\n

                                      \n
                                    • Definition of the purchase price<\/strong><\/li>\n<\/ul>\n

                                      The purchase price of the metal is fixed once the purchase procedure has been completed by the METAL BANK. The final price is shown in the private area at the end of the process, indicating the grams obtained. Please note that the final purchase price may differ from the indicative selling price, changing the grams purchased upward or downward based on market trends at the conclusion of the procedure.<\/p>\n

                                        \n
                                      • Minimum purchase weight<\/strong><\/li>\n<\/ul>\n

                                        The METAL BANK purchases (unless otherwise agreed between the parties) LBMA physical gold in 2g units at a time. The client may in any case request that the purchased metal be melted into bars of a different weight.<\/p>\n

                                          \n
                                        1. PROCEDURES FOR THE PURCHASE AND SALE OF GOLD<\/strong><\/li>\n<\/ol>\n

                                          The gold sale process can take place in two ways:<\/p>\n

                                            \n
                                          • Sale of gold held on behalf of the client in custody with the METAL BANK<\/li>\n
                                          • Sale of gold purchased from the METAL BANK and held in the client’s possession<\/li>\n<\/ul>\n
                                              \n
                                            • sale of gold held in custody <\/strong><\/li>\n<\/ul>\n

                                              For clients who have chosen to activate gold custody with the METAL BANK, there are various options for managing the sale of gold owned by the client and held in custody in the METAL BANK’s vaults.<\/p>\n

                                              In this case, the client can, through their own private area, access the sale function and determine how many grams to sell. The system provides an “INDICATIVE SELLING PRICE”.<\/p>\n

                                              The indicative selling price is based on the latest London fixing quotation for the per-gram price of LBMA gold, and displays the value associated with the indicative price based on the number of grams put up for sale.<\/p>\n

                                              This is an indicative price because, during the sale procedure, the public fixing price may move up or down, consequently changing the amount shown in the indicative selling price.<\/p>\n

                                              If the client wishes to proceed by sending the sell order to the system, they must confirm it by entering the OTP code sent to their mobile phone.<\/p>\n

                                              IMPORTANT<\/strong>: once the sell order has been executed and confirmed by entering the OTP code, it will no longer be possible to recall the order, even though the sale is actually processed over a period of time following the order confirmation.<\/p>\n

                                               <\/strong><\/p>\n

                                                \n
                                              • Execution times for the sale of gold held in custody<\/strong><\/li>\n<\/ul>\n

                                                Once the client confirms and sends the sell order through the private area, we process the execution immediately. However, the sale process does not always complete instantly. For this reason, it may take between 7 and 10 business days in the event of a large-scale sale of the deposit.<\/p>\n

                                                For all those who are part of the MEMBER ALPHA<\/strong> section (the highest level of priority and assistance), complementary services are available that provide access to a priority process ahead of the volume of orders received by the METAL BANK and reduce the sale process to 72 hours. Please refer to the ALPHA section for information on the terms and conditions of use.<\/p>\n

                                                 <\/strong><\/p>\n

                                                 <\/strong><\/p>\n

                                                  \n
                                                • Process for the settlement of funds generated by the sale<\/strong><\/li>\n<\/ul>\n

                                                  Once the physical gold sale process is completed, the system records the final selling price relative to the London fixing. The amount collected by the METAL BANK is transferred directly to the bank details provided by the client as the main account for the settlement of the fiat funds received.<\/p>\n

                                                  The METAL BANK does not charge any fee for the transaction generated by the sale but may apply banking costs in connection with the transfer of funds. Please refer to the current fees published in the “fees and charges” section for information on any amounts charged for sending the transfer of funds to your bank. The METAL BANK accepts no responsibility for any costs that the receiving bank may apply for internal transfers.<\/p>\n

                                                   <\/strong><\/p>\n

                                                    \n
                                                  • Differences between the purchase price and the selling price of gold held on deposit<\/strong><\/li>\n<\/ul>\n

                                                    It may happen that the selling price is lower than the purchase price. It should not be forgotten that the purchase price is based on the “public selling price”, which is made up of the London fixing price plus the costs applied by the METAL BANK, such as custody costs, insurance costs, storage costs, etc. For this reason, it is important to always bear in mind that selling within a short period of time may generate this discrepancy, which we invite you to take into account.<\/p>\n

                                                     <\/strong><\/p>\n

                                                      \n
                                                    • DUO Service<\/strong><\/li>\n<\/ul>\n

                                                      DUO is one of the services offered by the METAL BANK that allows you to obtain liquidity without selling the gold held on deposit.<\/p>\n

                                                      Indeed, DUO (if activated) allows the gold on deposit to be locked in exchange for an early settlement into your fiat current account. Please refer to the DUO regulations in the general terms and conditions.<\/p>\n

                                                        \n
                                                      • Sale of gold held by the client<\/strong><\/li>\n<\/ul>\n

                                                        The METAL BANK does not normally purchase gold originating from outside its own deposits or certified LBMA suppliers. For this reason, as a matter of policy, it does not purchase gold held directly by the client, even in the case of bars purchased directly from us.<\/p>\n

                                                        However, at the discretion of the METAL BANK, if it is agreed to initiate the gold purchase process, such purchase may be subject to additional costs resulting in a repurchase price lower than the London fixing.<\/p>\n

                                                          \n
                                                        1. CUSTODY PLANS <\/strong><\/li>\n<\/ol>\n

                                                          Clients who purchase gold may make use of the custody plans offered by the METAL BANK. The Custody Service is a paid service subject to different fees depending on the plan selected.<\/p>\n

                                                          The Custody Service is a service that allows you to purchase LBMA physical gold and have it allocated at the same METAL BANK where you purchased the gold, which will keep it in custody for you, allocating it every time you purchase gold above 2g.<\/p>\n

                                                          The METAL BANK offers various services and different types of custody plans, in order to best optimise the needs of all potential clients. Please review the features of each plan in the relevant section and select the one that best suits your needs. Make sure you have understood the costs involved, the duration of the lock-up period if any, any restrictions that may apply, etc.<\/p>\n

                                                          IMPORTANT<\/strong>: the gold you purchase and place into Custody is not allocated through a process of dividing a single bar among multiple clients. The advantage of purchasing 2g at a time allows the gold to be allocated to its actual owner. For this reason, our custody arrangement provides for the purchased gold to be assigned a “UNIQUE SERIAL CODE”, which makes it possible to physically identify the 2g bar you purchased, making you, to all effects, the sole owner of that specific and unique bar.<\/p>\n

                                                          For this reason, even if in a single purchase you buy more than two grams, your private area will show all the bars making up your purchase, each with a unique code assigned, thereby guaranteeing full ownership.<\/p>\n

                                                          Please note that, unlike bank deposits, the custody of LBMA physical gold does not suffer losses and is entirely separate from the financial management of the METAL BANK; in the event of insolvency, it is not subject to the \u20ac100,000 coverage limit imposed on banks. In the case of physical gold custody, the coverage extends to the full actual value held.<\/p>\n

                                                            \n
                                                          1. CUSTODY PLANS WITH LOCK-UP<\/strong><\/strong><\/li>\n<\/ol>\n

                                                            Custody plans with LOCK-UP are characterised by the client’s decision not to sell the metal held on deposit for a contractually agreed period of time, which may be 12, 24, 36 or 48 months.<\/p>\n

                                                            For this restricted deposit period, the METAL BANK applies a range of discounts to the activation cost, custody cost, and manufacturing or certificate issuance costs.<\/p>\n

                                                            The plans vary depending on the lock-up period and maintain the same custody conditions for the allocated gold.<\/p>\n

                                                              \n
                                                            1. CUSTODY PLANS WITH SCHEDULED PERIODIC SALE<\/strong><\/li>\n<\/ol>\n

                                                              One of the custody plans designed by the METAL BANK allows for the automation of a partial monthly periodic sale of the gold held. The gold allocated for monthly sale corresponds to a portion of the gold held on deposit that remains restricted for a period of time (lock-up) and cannot be sold during that period.<\/p>\n

                                                                \n
                                                              1. QUOTATION AND PUBLIC SELLING PRICE<\/strong><\/li>\n<\/ol>\n

                                                                The METAL BANK quotes the public selling price starting from the London fixing, adding to that price the costs based on the services selected by the client. Accordingly, the quotation shown by the METAL BANK as the “PURCHASE PRICE” quotation is, in fact, the “PUBLIC SELLING PRICE”. In addition, we have the SALE price, which is, in fact, the value of the London Fixing.<\/p>\n

                                                                IMPORTANT<\/strong>: the public selling price is always higher than the London fixing value, as it includes opening, issuance, custody costs, etc.<\/p>\n

                                                                  \n
                                                                1. FIXING<\/strong><\/li>\n<\/ol>\n

                                                                  The gold fixing is the official mechanism, managed by the LBMA (London Bullion Market Association), used to set the reference price of gold twice a day (at 10:30 and 15:00 GMT) in London. This value serves as a global benchmark for the trading of physical gold and derivatives, ensuring transparency and a common price at international level, to which the METAL BANK applies a mark-up (the differential between the London market fixing price and the public selling price applied by the METAL BANK \u2014 known as the premium), thereby determining the public selling price.<\/p>\n

                                                                    \n
                                                                  1. SERVICE COSTS<\/strong><\/li>\n<\/ol>\n

                                                                    The METAL BANK applies costs for its services, to be added to the price of the gold actually purchased. These costs vary depending on the services requested at the time the deposit is opened.<\/p>\n

                                                                    We invite you to check the price list published by the METAL BANK in the dedicated “Costs and Fees” section of the public website. The published costs may be subject to changes and discounts at the sole discretion of the METAL BANK.<\/p>\n

                                                                      \n
                                                                    1. DELIVERY AND SHIPPING COSTS<\/strong><\/li>\n<\/ol>\n

                                                                      You may decide not to activate the custody services, but instead make use of the bar-forming and shipping service to have the metal delivered to your home address.<\/p>\n

                                                                      This request requires you to provide us with the desired bar size and your home address so that we can ship the purchased gold to you.<\/p>\n

                                                                      You will be shown the costs you will need to bear before making the money transfer for the purchase, which must include the costs quoted by us.<\/p>\n

                                                                      Delivery is handled through the use of specialised valuables carriers that will deliver the gold to your home in complete safety. In addition to armed escort, these specialised carriers use armoured vehicles and specific insurance coverage designed to ensure delivery with the maximum possible security.<\/p>\n

                                                                        \n
                                                                      1. THE MEMBER ALPHA SECTION<\/strong><\/li>\n<\/ol>\n

                                                                        The MEMBER ALPHA section is a membership that provides preferential access to the METAL BANK’s services. The cost is updated on a yearly basis and shown in the Membership section.<\/p>\n

                                                                        MEMBER ALPHA enjoys priority access to services ahead of all other clients, as well as the possibility of receiving additional exclusive services reserved solely for ALPHA MEMBERS.<\/p>\n

                                                                        Below is a list of some of the exclusive services you will be able to access:<\/p>\n\n\n\n\n\n\n\n\n\n
                                                                         <\/td>\n\n

                                                                        Standard<\/p>\n<\/td>\n

                                                                        		\n

                                                                        ALPHA MEMBER<\/p>\n<\/td>\n<\/tr>\n

                                                                        \n

                                                                        Gold sale<\/p>\n<\/td>\n

                                                                        		\n

                                                                        3-10 days<\/p>\n<\/td>\n

                                                                        		\n

                                                                        Max 72 hours<\/p>\n<\/td>\n<\/tr>\n

                                                                        \n

                                                                        Gold purchase<\/p>\n<\/td>\n

                                                                        		\n

                                                                        1 time per week<\/p>\n<\/td>\n

                                                                        		\n

                                                                        48 hours from the order<\/p>\n<\/td>\n<\/tr>\n

                                                                        \n

                                                                        Personalised advisory service<\/p>\n<\/td>\n

                                                                        		\n

                                                                        Chargeable<\/p>\n<\/td>\n

                                                                        		\n

                                                                        Included<\/p>\n<\/td>\n<\/tr>\n

                                                                        \n

                                                                        Repurchase agreement<\/p>\n<\/td>\n

                                                                        		\n

                                                                        Chargeable<\/p>\n<\/td>\n

                                                                        		\n

                                                                        Included<\/p>\n<\/td>\n<\/tr>\n

                                                                        \n

                                                                        Customised bars<\/p>\n<\/td>\n

                                                                        		\n

                                                                        Chargeable<\/p>\n<\/td>\n

                                                                        		\n

                                                                        50% discount<\/p>\n<\/td>\n<\/tr>\n

                                                                        \n

                                                                        Home delivery of the metal<\/p>\n<\/td>\n

                                                                        		\n

                                                                        Chargeable<\/p>\n<\/td>\n

                                                                        		\n

                                                                        50% discount<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                                                          \n
                                                                        1. THE DUO PROGRAMME<\/strong><\/li>\n<\/ol>\n

                                                                          DUO is the service that allows the Client, as owner of the gold held in custody with the METAL BANK, to avoid selling the gold in case of a need for liquidity.<\/p>\n

                                                                          This service can be activated directly from your private area by selecting the amount you wish to activate, placing your gold on deposit under lock-up.<\/p>\n

                                                                          The DUO system automatically calculates the maximum amount you can access relative to the value of the deposit held with the METAL BANK.<\/p>\n

                                                                          Activation of the DUO service involves an activation cost and a maintenance cost that affects the custody of the gold held. Please refer to the “Costs and Fees” section for full information before accessing this service.<\/p>\n

                                                                          Activation requires your acceptance of the specific general terms and conditions of use for the DUO service.<\/p>\n

                                                                          The system displays a pop-up during the activation process, which must be validated using an OTP confirmation code, without which the service cannot be activated.<\/p>\n

                                                                            \n
                                                                          1. REPURCHASE SERVICE AT AN AGREED PRICE<\/strong><\/li>\n<\/ol>\n

                                                                            One of the services offered by the METAL BANK consists of the ability to lock in the selling price (the repurchase price for the METAL BANK) as of a set date. At present, this service is available for the “PREMIUM PLUS” and “RELAX” plans. Accordingly, at the end of the lock-up period, the repurchase price of the metal will be settled as indicated in the deposit agreement, with no possibility of variation, save for a different agreement between the parties, which must in any case be unilaterally accepted by the METAL BANK. The repurchase of the metal at a price fixed between the METAL BANK and the client is a service that requires an additional cost on top of that used for the purchase of the metal. We invite you to review the costs relating to this service in the table published on the “Costs and Fees” website page<\/p>\n

                                                                              \n
                                                                            1. ACCESS TO THE PRIVATE AREA<\/strong><\/li>\n<\/ol>\n

                                                                              Once you have successfully completed the onboarding stages, you will have access to the private area where you can manage your ACCOUNT and the deposit plans you have chosen. From this area you will be able to purchase, sell and custody your gold, and activate the various services offered by the METAL BANK. For any activity requiring you to place an instruction order, you will be asked to confirm it using an OTP code sent to your phone.<\/p>\n

                                                                              If you receive an OTP code and you are not the one operating in the private area, you must cancel the old access codes and reactivate new ones to prevent fraudulent access. If necessary, you can request support from our technical department by emailing help@realmoneyeu.com.<\/p>\n

                                                                                \n
                                                                              1. SERVICE DISRUPTIONS AND COMPLAINTS<\/strong><\/li>\n<\/ol>\n

                                                                                Despite our commitment to offering you the best services and the best experience in managing your custody plans, it may happen that, despite our best efforts, a service disruption occurs in relation to activities within the METAL BANK. Service disruptions may occur due to technical, administrative, logistical issues, etc. To obtain a prompt resolution to any issue that may be the subject of a disruption, in addition to having the email address of each relevant department, you may contact the “Complaints” department through the dedicated section on the website. Staff within the METAL BANK will get in touch with you to resolve any issue as quickly as possible.<\/p>\n

                                                                                  \n
                                                                                1. RESTRICTIONS ON ACCOUNT USE<\/strong><\/li>\n<\/ol>\n

                                                                                  For various reasons, we may find ourselves required, at our discretion, to restrict the use of your Account. Security issues may arise from our systems. Alternatively, we may need to request additional information regarding your professional profile or your identity.<\/p>\n

                                                                                  In such cases, you may be asked to provide documents that are necessary to complete our due-diligence process and that will allow the operability of your Account to be restored.<\/p>\n

                                                                                    \n
                                                                                  1. TERMINATION OF THE ACCOUNT<\/strong><\/li>\n<\/ol>\n

                                                                                    At any time, you may close your Account and either collect all the gold at your home address or sell it in full and request a transfer to your bank current account.<\/p>\n

                                                                                    Similarly, the METAL BANK may decide to close your Account without having to give reasons. In such a case, the METAL BANK will send you a communication by email, SMS and, if necessary, also by ordinary mail, informing you of the decision to terminate your Account. From the time of the communication, the account will be frozen and you will be asked what you wish to do with the gold on deposit. You may sell it and receive the funds into your bank account, or collect it at your home address as registered with us. If, within 30 days of the communication, none of the above options has been indicated, the METAL BANK will in any case terminate your Account and, 90 days after termination, will send a money transfer generated from the sale of your gold to your bank current account as registered with us.<\/p>\n

                                                                                      \n
                                                                                    1. ADVISORY ACTIVITIES<\/strong><\/li>\n<\/ol>\n

                                                                                      The METAL BANK offers a personalised advisory service to its clients through specialised, properly trained advisors, who provide appropriate information on the services, opportunities and degrees of risk present in the physical gold sector.<\/p>\n

                                                                                      This advisory activity does not fall within the scope of MiFID or MiCAR regulations. However, our advisors will ask you to complete the due diligence questionnaire to better understand your knowledge of physical gold, your risk appetite, the acceptable time horizon according to the applicable lock-up periods, etc.<\/p>\n

                                                                                      It is of primary importance that you provide as much information as possible so that we can offer you the best possible advisory service.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t","protected":false},"excerpt":{"rendered":"

                                                                                      WEBSITE TERMS AND CONDITIONS OF USE HOLDER OF THE METAL BANK The provider of the LBMA physical gold sales service that offers THE REAL MONEY’s clients services and products related to physical gold is Real Money Europe Limited LTD Registration number 813181, Block 4 Harcourt Centre, Harcourt Road, Dublin 2, D02 HW77, Dublin, Ireland. Physical gold METAL BANK. Every product and activity relating to the sale, purchase, supply, custody and advisory services on LBMA gold is managed by Real Money Europe, subject to Irish law. All references on the REALMONEYEU.COM platform relating to LBMA physical gold refer to products and Services provided by Real Money Europe Ltd. Hereinafter, also the METAL BANK. The METAL BANK oversees the deposits opened by clients for the custody of the physical gold they have purchased. The deposit plans may offer different options and vary in terms of volume, activation cost, custody cost, insurance costs, management costs, etc. The METAL BANK may, at its discretion, modify, remove, suspend or create deposit plans and the general terms and conditions associated with them. The custody of the gold purchased by clients is managed by the METAL BANK at its discretion, including through the use of external maximum-security LBMA vaults, taking into account logistics and pricing or more favourable services, without thereby limiting the maximum possible guarantee and security for the protection of the client. SERVICES AND CUSTODY PLANS The METAL BANK offers various services as indicated below: Purchase of LBMA physical gold Delivery of purchased gold to the client’s home address Custody of purchased gold in maximum-security vaults Management of the purchase and sale processes for gold held in custody Administration of the deposit plan on behalf of the Ultimate Beneficial Owner Issuance of deposit ownership certificates Issuance of digital blockchain certificates of the deposit’s valuation with a certified date Creation of bars in different formats Customised custody services (in-out, premium plus, stability, future, relax, etc.) Purchase price protection ONBOARDING PROCESS AND AML OBLIGATIONS   Anti-Money Laundering European AML regulation KYC \/ KYB Verification Natural and legal persons Risk-Based Approach Proportional to risk 3.1 WHY WE ARE SUBJECT TO AML REGULATIONS The METAL BANK (hereinafter “METAL BANK” or “the Company”) is committed to combating money laundering (AML \u2014 Anti-Money Laundering) and terrorist financing (CFT \u2014 Combating the Financing of Terrorism). This is a fundamental commitment, not merely a regulatory obligation. We believe that a healthy and transparent precious metals market requires responsible operators who adopt high standards of customer due diligence. This Policy transparently describes our approach to preventing financial crime, the procedures we adopt to verify customer identity, and the criteria we use to assess the risk associated with each business relationship. Our commitment: the METAL BANK ensures that its activities of buying, selling and safekeeping physical gold, including through qualified depositaries, are carried out in full compliance with applicable regulations and are not used for unlawful activities, in order to protect our clients and the integrity of the gold market. 3.2 REGULATORY REFERENCES This Policy has been drafted in accordance with the following regulatory framework: Regulation Description EU Reg. 2024\/1624 (AMLR) New European regulatory framework on anti-money laundering, which will introduce harmonised rules at EU level, with phased application starting in 2027 GDPR \u2014 EU Reg. 2016\/679 Protection of personal data \u2014 legal basis for the processing of KYC\/KYB data FIU Communications Anomaly indicators for suspicious transactions in the precious metals and investment gold sector FATF Standards (2021+2024) International recommendations on the risk-based approach for METAL BANK \u2014 methodological reference 3.3 GLOSSARY Below are the main definitions and acronyms used in this Policy: Acronym Term Definition AML Anti-Money Laundering Anti-money laundering: the set of measures aimed at preventing and combating the laundering of proceeds from unlawful activities CFT Combating the Financing of Terrorism Combating the financing of terrorism ML\/TF Money Laundering \/ Terrorist Financing Money laundering and terrorist financing: the two main risks that AML\/CFT procedures aim to prevent KYC Know Your Customer Verification of the identity of an individual client: collection and verification of identification data, documentation and the source of funds KYB Know Your Business In-depth verification of a corporate client: collection and verification of corporate data, directors and the ultimate beneficial owner CDD Customer Due Diligence Customer due diligence: standard procedure applied to all clients EDD Enhanced Due Diligence Enhanced due diligence: in-depth procedure for high-risk clients SDD Simplified Due Diligence Simplified due diligence: streamlined procedure for clients with documented low risk PEP Politically Exposed Person Politically Exposed Person: an individual who holds or has held prominent public functions UBO Ultimate Beneficial Owner Ultimate Beneficial Owner: the natural person who owns or controls a legal entity (holding > 25%) AMLCO AML Compliance Officer AML Compliance Officer: oversight of AML\/CFT procedures FIU Financial Intelligence Unit Authority that receives Suspicious Transaction Reports (STRs) SOS Suspicious Transaction Report Communication sent to the UIF when an ML\/TF transaction is suspected LBMA London Bullion Market Association International association that certifies gold and silver refineries \u2014 reference standard for the custody of metals 3.4 WHY WE VERIFY YOUR IDENTITY Identity verification is not merely a legal obligation: it is the primary tool through which the METAL BANK protects its clients and safeguards the integrity of the physical gold market. The main risk for a METAL BANK is being unintentionally involved in unlawful activities. These controls protect both the METAL BANK and \u2014 above all \u2014 our clients, ensuring a safe and reliable environment for investing in physical gold. 3.5 OUR APPROACH: RISK-BASED AND HUMAN-FIRST The Company adopts a risk-based approach (RBA), in accordance with the FATF Recommendations for METAL BANKs (updated to 2024) and applicable supervisory provisions. This means that: We do not treat all clients in the same way: those presenting higher-risk characteristics are subject to more in-depth checks; Those with a documented low-risk profile may access services through streamlined procedures; Compliance resources are concentrated where risk is greatest, without unnecessarily burdening the experience of low-risk clients. Our approach combines face-to-face identification \u2014 carried out by<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-6678","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/pages\/6678","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/comments?post=6678"}],"version-history":[{"count":9,"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/pages\/6678\/revisions"}],"predecessor-version":[{"id":6993,"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/pages\/6678\/revisions\/6993"}],"wp:attachment":[{"href":"https:\/\/demo.realmoneyeu.com\/en\/wp-json\/wp\/v2\/media?parent=6678"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}