GLOSSARY

INTRODUCTORY NOTES

This Glossary is drawn up in connection with the activity of REAL MONEY EUROPE LIMITED as a Metal Bank a Designated Person under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021. The document provides definitions of the technical, regulatory and operational terms used in the contractual and informational documentation relating to the services offered.

This Glossary forms an integral part of the Terms and Conditions for the Services offered by REAL MONEY EUROPE LIMITED. In the event of a conflict between the definitions contained in this Glossary and those contained in the applicable regulations cited, the regulatory definitions shall prevail.

Terms below are listed in English alphabetical order.

— A —

Anomaly Indicators

Patterns of activity or behaviour on the part of customers that are indicative of anomalous conduct, intended to assist in assessing potential indications of money laundering or terrorist financing.

Anti-Money Laundering Function

The function, forming an integral part of the second-level internal control system, responsible for preventing and combating money laundering and terrorist financing.

Anti-Money Laundering Policy

The document defined by the management body and approved by the body responsible for strategic oversight, in accordance with the provisions on organisation, procedures and internal controls aimed at preventing the use of intermediaries for the purposes of money laundering and terrorist financing.

— B —

Beneficial Owner (UBO — Ultimate Beneficial Owner)

The natural person or persons, other than the Customer, on whose behalf, ultimately, the business relationship is established, the professional service is provided, or the transaction is carried out. For legal persons, the Beneficial Owner is considered to be the natural person who holds, directly or indirectly, more than 25% of the share capital or voting rights.

Business Relationship

An ongoing relationship, arising in the course of the activity carried out by obliged entities, which is not limited to a single transaction.

— C —

Cash

Banknotes and coins, in euro or in foreign currency, having legal tender status. REAL MONEY EUROPE LIMITED does not accept cash payments under any circumstances.

Centralised AML Register

A register, compiled and maintained by means of IT systems, in which all information obtained in fulfilment of customer due diligence obligations is stored centrally, in accordance with the principles set out in the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021 and applicable guidance. REAL MONEY EUROPE LIMITED retains data in the Centralised AML Register for a minimum period of 5 years from the termination of the relationship, pursuant to Section 55 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021.

Compliance Function

The function responsible for overseeing, on a risk-based approach, the management of non-compliance risk in relation to the business activities of REAL MONEY EUROPE LIMITED, verifying that procedures are adequate to prevent such risk. An integral part of the internal control system.

Compliance Risk

A specific requirement imposed by a given piece of legislation, non-compliance with which may result in judicial or administrative sanctions, material financial loss or reputational damage arising from breaches of mandatory rules (laws, regulations) or self-regulatory standards.

Customer / Clientele

The party that establishes a business relationship with, or carries out transactions with, REAL MONEY EUROPE LIMITED.

Customer Due Diligence (KYC — Know Your Customer / KYB — Know Your Business)

An activity consisting of:

verifying the identity of the Customer, any Executor and any Beneficial Owner on the basis of documents, data or information obtained from a reliable and independent source;
obtaining information on the purpose and intended nature of the business relationship and, where relevant under a risk-based approach, of the occasional transaction;
conducting ongoing monitoring throughout the course of the business relationship.

KYC refers to the verification of natural persons; KYB to the verification of legal persons. REAL MONEY EUROPE LIMITED applies three progressive levels of verification.

— D —

Directors (formerly “Senior Manager”)

The members of the Board of Directors of REAL MONEY EUROPE LIMITED. The Irish corporate structure does not provide for the “Senior Manager”: the equivalent supervisory functions over relationships with high-risk Customers are assigned to the Directors. Under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021, final approval of relationships with PEP customers and high-risk customers is the exclusive responsibility of the Directors of REAL MONEY EUROPE LIMITED.

— E —

Enhanced Due Diligence (EDD)

An enhanced customer due diligence measure required by law in respect of categories of high-risk customers. REAL MONEY EUROPE LIMITED applies EDD on a mandatory basis to: PEPs (Politically Exposed Persons) and their family members and close associates; customers resident or operating in high-risk third countries (FATF and European Commission lists); transactions exceeding the threshold defined in the Risk Appetite Framework; and customers whose risk profile has been reassessed as high. EDD includes: a direct interview, documentation on the source of overall wealth, and bank references. Final approval is the exclusive responsibility of the Directors of REAL MONEY EUROPE LIMITED.

Executor

The party authorised to act in the name and on behalf of the Customer, or to whom powers of representation have otherwise been granted enabling them to act in the name and on behalf of the Customer.

— F —

FATF (Financial Action Task Force)

A body established under the OECD, specialised in the prevention and combating of money laundering, terrorist financing and the financing of weapons of mass destruction proliferation. The FATF lists of high-risk AML/CFT countries are used by REAL MONEY EUROPE LIMITED for the purpose of client risk classification. Website: www.fatf-gafi.org

Financial Advisor

Independent financial advisors authorised to provide off-premises advisory services, who may offer advice to their clients on the services offered by REAL MONEY EUROPE LIMITED. They carry out independent advisory activity and act autonomously in relation to their own clients, without any employment relationship with REAL MONEY EUROPE LIMITED.

For the purposes of AML/CFT legislation (Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021), the Financial Advisor falls within the definition of Personnel and must comply with the same customer due diligence procedures applicable to REAL MONEY EUROPE LIMITED’s internal staff. REAL MONEY EUROPE LIMITED remains responsible for the adequacy of KYC/KYB verification even where the documentation is collected through a Financial Advisor.

FIU Ireland — Financial Intelligence Unit

The national unit responsible for the prevention and combating of money laundering and terrorist financing in Ireland, corresponding to the unit referred to in other jurisdictions (e.g. Italy) as the UIF — Unità di Informazione Finanziaria. FIU Ireland is embedded within the Garda National Economic Crime Bureau (GNECB), part of An Garda Síochána (the Irish national police service). REAL MONEY EUROPE LIMITED is required to submit to FIU Ireland, and concurrently to the Revenue Commissioners, any Suspicious Transaction Reports (STRs) identified in the course of its business, pursuant to Section 42 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021, without disclosing this to the client concerned (prohibition on tipping off — Section 49 of the same Act). Website: www.fiu-ireland.ie (goAML reporting platform).

Fixing (LBMA Fixing)

The official gold price set twice a day by the London Bullion Market Association (LBMA) through an electronic auction, expressed in US dollars per troy ounce. It constitutes the primary reference for calculating the price applied by REAL MONEY EUROPE LIMITED to each purchase or sale transaction carried out on behalf of the Customer on the official dates of the 10th and 25th of each month. The price per gram communicated to the client prior to completion of the transaction is calculated on the basis of the fixing recorded on those dates.

Freezing of Funds

The prohibition, under European Union regulations and Irish national law, on the movement, transfer, alteration, use of, or access to funds in a way that would change their volume, amount, location, ownership, possession, nature, destination, or any other change that would enable the use of the funds.

Funds

Financial assets and benefits of any kind, including those held through an intermediary natural or legal person, including, by way of example: cash, cheques, monetary claims, payment orders, deposits, negotiable securities, financial instruments and insurance policies.

— H —

High-Risk Third Countries

Countries not belonging to the European Union whose legal frameworks present strategic deficiencies in their national regimes for the prevention of money laundering and terrorist financing, according to the up-to-date lists issued by the FATF and the European Commission. Clients resident or operating in such countries are subject to mandatory Enhanced Due Diligence (EDD).

— I —

Identification Data of the Customer, the Beneficial Owner and the Executor

The first and last name, place and date of birth, registered residential address and, where different, domicile, and, where assigned, the tax identification number (or PPS Number/Tax Reference Number for Irish persons) of the Customer, and, where applicable, of the relevant Beneficial Owner and Executor. In the case of persons other than natural persons: name, registered office, and registration number with the Companies Registration Office (CRO) or equivalent register.

Internal Audit Function

The function responsible for overseeing, from a third-level control perspective, the ongoing conduct of operations and the evolution of risks, assessing the completeness, adequacy and reliability of the organisational structure and of the Internal Control System. It issues recommendations to the corporate bodies.

Internal Control System

The set of rules, functions, structures, resources, processes and procedures designed to ensure: verification of the implementation of corporate strategies and policies; containment of risk within the limits of the Risk Appetite Framework; safeguarding of asset value; the effectiveness and efficiency of business processes; and compliance of operations with the law and applicable supervisory regulations.

Investment Gold

Under EU VAT legislation (Directive 2006/112/EC, Title XII, Chapter 5, Articles 344 and 346), as transposed in Ireland by the Value-Added Tax Consolidation Act 2010 (Section 90(1) and Schedule 1, paragraph 9(1)), investment gold means: (i) gold in the form of a bar or wafer of weights accepted by the bullion markets, of a purity equal to or greater than 995 thousandths, whether or not represented by securities; (ii) gold coins of a purity equal to or greater than 900 thousandths, minted after 1800, that are or have been legal tender in their country of origin, and are normally sold at a price that does not exceed the open market value of the gold contained in them by more than 80%. Investment gold constitutes the exclusive subject matter of the intermediation and custody activities carried out by REAL MONEY EUROPE LIMITED as a Precious Metals Dealer.

REAL MONEY EUROPE LIMITED deals exclusively in investment gold under applicable EU legislation. Transactions in investment gold are exempt from VAT under the Value-Added Tax Consolidation Act 2010 (special scheme for investment gold).

— L —

LBMA (London Bullion Market Association)

An international body based in London that sets global standards for the trading, certification and pricing of gold and other precious metals. LBMA certification of refineries and depositaries is a mandatory requirement for the execution of purchases by REAL MONEY EUROPE LIMITED. The LBMA Fixing represents the official reference price for all investment gold transactions. Website: www.lbma.org.uk

— M —

Money Laundering Risk

The risk arising from the breach of legal, regulatory or self-regulatory provisions aimed at preventing the use of the financial system for the purposes of money laundering, terrorist financing, or the financing of weapons of mass destruction proliferation programmes.

— P —

Politically Exposed Persons (PEP)

Natural persons who are or have, within the preceding year, ceased to be entrusted with prominent public functions, together with their family members and persons known to be closely associated with such persons, within the meaning of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021. PEP clients are subject to mandatory EDD and require the approval of the Directors of REAL MONEY EUROPE LIMITED.

PSP (Payment Service Provider)

An entity authorised under Directive (EU) 2015/2366 (PSD2), as transposed in Ireland by the European Union (Payment Services) Regulations 2018 (S.I. No. 6 of 2018), to provide payment services. Examples: banks, payment institutions, e-money institutions. REAL MONEY EUROPE LIMITED is not a PSP and does not provide payment services within the meaning of PSD2.

— R —

Refinery / Depositary

The wholesale physical gold supplier, certified by the London Bullion Market Association (LBMA), from which REAL MONEY EUROPE LIMITED purchases gold on behalf of its clients and to which it entrusts physical custody. LBMA certification guarantees compliance with international standards of quality, purity and traceability of the precious metal.

Remote Operations

Activities carried out without the physical presence of the client and REAL MONEY EUROPE LIMITED’s designated staff, including identity verification by video call to the extent permitted by the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021.

Risk-Based Approach

An approach whereby competent authorities and undertakings identify, assess and understand the money laundering risks to which undertakings are exposed and adopt mitigating measures commensurate with those risks.

Risk Factors

Variables which, individually or in combination, may increase or decrease the money laundering risk arising from individual business relationships or occasional transactions.

Risk Score

A numerical score assigned by REAL MONEY EUROPE LIMITED to each client on the basis of the customer due diligence process (KYC/KYB), which determines the client’s AML risk profile. The calculation weighs: the nature and purpose of the business relationship, the source of funds and wealth, the geographic area of residence, and the client category (e.g. PEP, institutional client, private individual). The Risk Score guides the applicable verification measures and any activation of Enhanced Due Diligence (EDD).

— S —

Security Deposit

A sum paid by the Customer as security for the performance of contractual obligations under the Instalment Plan, equal to 10% of the total value of the plan. The security deposit is used by REAL MONEY EUROPE LIMITED to complete purchases on the pre-set dates (the 10th and the 25th of each month) and is returned to the Customer at the end of the plan, subject to verification that all payments due have been correctly made.

Shell Bank

A bank (or a financial institution carrying out equivalent activities) that has no physical presence in the country in which it is incorporated and authorised, and which is unaffiliated with a regulated financial group subject to effective consolidated supervision.

Structured Transaction

A transaction that is unitary in economic terms, of an amount equal to or exceeding the thresholds set out in the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021, carried out through multiple transactions each individually below such thresholds, executed at different times within a limited period set at seven days. REAL MONEY EUROPE LIMITED’s monitoring system automatically detects structured transactions, which constitute an indicator of potential money laundering subject to a reporting obligation to FIU Ireland.

Suspicious Transaction (STR — Suspicious Transaction Report)

A transaction which, by reason of its characteristics, size, nature, or connection with other transactions, gives rise to a belief, suspicion, or reasonable grounds for suspicion that money laundering or terrorist financing is taking place. Where a suspicious transaction is identified, REAL MONEY EUROPE LIMITED is required by law to submit a Suspicious Transaction Report (STR) to the Financial Intelligence Unit (FIU Ireland) and to the Revenue Commissioners, pursuant to Section 42 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021. Such a report may not be disclosed to the client concerned (prohibition on tipping off — Section 49 of the same Act).

— T —

Transaction

The carrying out of any dealings of an economic nature relating to the purchase, sale or custody of physical gold and other precious metals, including periodic payments made under accumulation plans, withdrawals, refunds of the security deposit, and any other movement of payment instruments connected with the performance of the services provided by REAL MONEY EUROPE LIMITED as a Precious Metals Dealer, a Designated Person under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021.

GLOSSARY

INTRODUCTORY NOTES

Terms below are listed in English alphabetical order.

GLOSSARY

INTRODUCTORY NOTES

Indice

— A —

— B —

— C —

— D —

— E —

— F —

— H —

— I —

— L —

— M —

— P —

— R —

— S —

— T —

GLOSSARY

INTRODUCTORY NOTES

Indice