1. Zero facilitation of unlawful conduct

GMZ does not knowingly support sanctions evasion, money laundering, terrorist financing, bribery, corruption, stolen minerals, fraudulent trade documents, tax crime or concealment of beneficial ownership.

2. Know your counterparty

• Legal identity, registry and operating address.
• Directors, authorised signatories and beneficial owners.
• Purpose, expected activity and transaction rationale.
• Licence, mandate, source of product and source of funds.
• Public-official, sanctions, adverse-media and criminal-risk indicators.

3. Enhanced-risk indicators

Examples include unexplained intermediaries, cash-intensive precious-metals or stones activity, secrecy jurisdictions without commercial reason, third-party payment, last-minute bank changes, inconsistent documents, unusual commissions, government influence, conflict areas, sanctioned routes or refusal to disclose ownership.

4. Sanctions screening

Relevant parties, beneficial owners, banks, vessels, locations and goods should be screened against applicable United Nations and national sanctions regimes. Screening is time-sensitive and must be repeated when facts change.

5. Anti-bribery

No user may offer, promise, request or accept an improper advantage to influence a public or private decision. Government fees, agents, gifts, travel, charitable contributions and success payments require transparent authority, records and legal review.

6. Payment controls

Payments should use verified accounts in the name of the lawful party, with consistent invoices and contracts. High-risk transactions may require regulated escrow, bank confirmation, source-of-funds evidence and independent compliance approval.

7. Recordkeeping and escalation

GMZ may retain compliance records, request clarification, reject or suspend activity and make legally required reports. GMZ does not promise confidentiality where disclosure is required by competent authority.

8. Member responsibility

GMZ screening is not a substitute for a member’s legal obligations or professional compliance programme.