Anti-Money Laundering Policy

American Wealth Bullion Group LLC d/b/a American Wealth Group (“AWG”), a Nevada limited liability company · 304 S. Jones Blvd., #7711, Las Vegas, NV 89107

1. Adoption of Compliance Program

This AML/CFT compliance program sets out how AWG prevents money laundering, terrorist financing, sanctions evasion, fraud, elder financial exploitation, corruption and other financial crimes. AWG’s senior management has approved this program in writing, as 31 CFR 1027.210(a) requires. AWG will make it available to the U.S. Department of the Treasury, through the Financial Crimes Enforcement Network (FinCEN) or its designee, on request.

AWG reviews its AML strategies and objectives on an ongoing basis and maintains an effective program. AWG holds itself to high standards of AML compliance. Management, employees, independent contractors and agents must follow these standards so that AWG’s products and services are never used for money laundering or terrorist financing.

Following this policy is fundamental to AWG’s compliance with:

• the Bank Secrecy Act, 31 U.S.C. 5311 et seq.;
• Section 352 of the USA PATRIOT Act, 31 U.S.C. 5318(h);
• FinCEN’s rules for dealers in precious metals, precious stones or jewels, 31 CFR Part 1027;
• 26 U.S.C. 6050I and 31 CFR 1027.330 (Form 8300 cash reporting);
• U.S. sanctions laws administered by the Office of Foreign Assets Control (OFAC), 31 CFR Chapter V;
• Nevada law, including NRS 207.195 (transactions involving proceeds of unlawful activity), NRS 200.5091 to 200.50995 (exploitation of older and vulnerable persons), NRS 41.1395 (civil liability for exploitation of older or vulnerable persons), NRS Chapter 599B (telephone sellers, including NRS 599B.270 to 599B.300 on elderly persons), NRS Chapter 598 (deceptive trade practices) and NRS 603A.200 to 603A.220 (security and destruction of records).

AWG also follows any added standards from its regulators that explain these duties.

2. Scope: Why AWG Is a Covered Dealer

Federal law requires a written AML program from any dealer that both buys and sells more than $50,000 of covered goods, including gold, silver, platinum and palladium bullion and coins, in a calendar year (31 CFR 1027.100 and 1027.210). AWG buys and sells physical precious metals for cash and IRA customers. AWG treats itself as a covered dealer from its first transaction and does not wait to reach the threshold.

This program covers every AWG transaction:

• cash (non-IRA) purchases;
• self-directed IRA purchases funded through a custodian;
• numismatic (rare) coin purchases made at a customer’s request;
• buybacks of metal from customers; and
• purchases from and sales to wholesalers.

AWG holds its Nevada telephone seller registration and bond (NRS 599B.080 to 599B.100), and the state and local business licenses required to buy and sell precious metals in Clark County and the City of Las Vegas, including licenses for buying metal back from the public.

3. Money Laundering Overview

Money laundering is defined as “the attempt to conceal or disguise the nature, location, source, ownership, or control of illegally obtained money.” Nevada makes it a crime to conduct a financial transaction with proceeds of unlawful activity to conceal their source or to promote unlawful activity (NRS 207.195). Terrorist financing is providing funds or other support to terrorists or terrorist organizations. Those funds may come from legitimate or illegitimate sources.

Three stages of money laundering. Using these stages, a person can make illegal funds look as if they came from a legal or legitimate source.

1. Placement: A person buys money orders, traveler’s checks, prepaid cards, money transfers or precious metals with funds from a crime.
2. Layering: A person moves money from one financial institution to another and changes its form through multiple transactions, making it hard to trace to its original source.
3. Integration: A person turns the money into a seemingly legitimate form, such as automobiles, businesses, real estate or precious metals, that can later be sold.

Precious metals attract launderers because they hold high value in a small, portable form and can be resold for funds that look legitimate. Numismatic coins carry an added risk: their price depends on grade and collector demand, so an inflated or deflated price can be used to move value between parties. Every AWG employee is responsible for watching for these risks.

4. Risk Assessment

AWG bases its policies, procedures and internal controls on a written assessment of the money laundering and terrorist financing risks of its business (31 CFR 1027.210(b)(1)). The Compliance Officer updates the assessment at least once a year and whenever AWG’s risk profile changes significantly, such as a new product, payment method, sales channel or state. The assessment considers:

1. The types of products AWG buys and sells, and the nature of its customers, suppliers, distribution channels and geographic locations.
2. The extent to which AWG transacts with parties other than established customers, established sources of supply, or other dealers subject to 31 CFR Part 1027.
3. Whether payment or account reconciliation is routed to or from accounts located in a jurisdiction that:
   • the Department of State has identified as a state sponsor of terrorism under 22 U.S.C. 2371;
   • an intergovernmental group of which the United States is a member, with U.S. concurrence, has designated as non-cooperative with international anti-money laundering principles; or
   • the Secretary of the Treasury has designated under 31 U.S.C. 5318A as warranting special measures.
4. FinCEN’s published national AML/CFT priorities, including fraud, cybercrime, corruption and terrorist financing (31 U.S.C. 5318(h)(4)).

AWG’s current risk profile.

• Products: bullion (bars, rounds and government-mint coins), plus numismatic coins sold only at a customer’s request for non-IRA purchases.
• Customers and channels: U.S. residents, by telephone and online.
• Payment: bank wire or ACH from the customer’s own account in the customer’s name, or funds sent directly from the customer’s IRA custodian. AWG does not accept cash, credit cards, cryptocurrency, money orders, traveler’s checks or third-party payments.
• Delivery: insured shipment to the customer’s verified address, or to an approved depository.

These controls make AWG lower-risk. They do not remove the risks of fraud, elder financial exploitation, identity theft, or scams in which a third party directs the customer. Numismatic orders are rated higher-risk and receive the enhanced review in Section 5.

5. Customer Identification and Due Diligence

Employees must obtain appropriate customer identification for every transaction. At a minimum, AWG:

• Collects the customer’s full legal name, date of birth, residential address, telephone number and email address.
• Verifies identity with an unexpired government-issued photo ID and confirms that the name on the ID matches the name on the bank or IRA account.
• For an entity or trust, identifies the entity, its authorized signer and, where reasonable, the individuals who own or control it.
• Confirms the source of funds and the purpose of the purchase in a recorded call before the order is final.
• Ships only to the customer’s verified address or to an approved depository. Any request to ship elsewhere requires Compliance Officer approval.
• Refuses, withdraws from or ends any transaction when a customer will not provide identification or complete and accurate information (31 CFR 1027.210(b)(1)(ii)).

Enhanced review for numismatic orders. AWG sells numismatic coins only after a customer’s own request. Before any numismatic order is final, AWG:

• obtains the customer’s signed numismatic disclosure and acknowledgment;
• documents the price basis, including the independent grading certification and a market price reference; and
• has the Compliance Officer review the order before it is confirmed.

6. Sanctions Screening (OFAC)

OFAC is part of the U.S. Department of the Treasury. It enforces U.S. government sanctions against countries, organizations and individuals. Sanctions programs often block assets to protect national security. Many sanctioned individuals, called Specially Designated Nationals (SDNs), are known drug traffickers and terrorists. All U.S. persons are prohibited from doing financial transactions with SDNs. The current list is published on the Treasury website at ofac.treasury.gov.

AWG screens every customer, wholesaler and other counterparty against the SDN list and OFAC’s other sanctions lists before the first transaction. AWG screens again before any buyback or payment out. A possible match goes to the Compliance Officer, and the transaction stops until the match is cleared. A confirmed match is blocked or rejected and reported to OFAC within 10 business days (31 CFR 501.603 and 501.604). AWG keeps sanctions records for 10 years under OFAC’s rule effective March 12, 2025, which extended the period from 5 to 10 years (31 CFR 501.601).

7. Suspicious Transactions and Red Flags

Employees are trained to identify transactions that may involve use of AWG to facilitate money laundering or terrorist financing (31 CFR 1027.210(b)(1)(ii)), including transactions that involve:

• Unusual payment methods, such as large amounts of cash, multiple or sequentially numbered money orders, traveler’s checks or cashier’s checks, or payment from third parties.
• Unwillingness by a customer or supplier to provide complete or accurate contact information, financial references or business affiliations.
• Attempts by a customer or supplier to keep an unusual degree of secrecy about the transaction, such as a request that normal business records not be kept.
• Purchases or sales that are unusual for the particular customer or supplier, or that type of customer or supplier.
• Purchases or sales that do not conform to standard industry practice.
• A request for a numismatic coin at a price that does not match its certified grade or market references, or a request to record a different price than the one paid.

Scam and elder-fraud red flags (2026). FinCEN Alert FIN-2026-Alert005 (September 3, 2026) warns that scammers direct victims to buy precious metals. Employees must also escalate any of the following:

• A customer says a government agent, law enforcement officer, bank employee or “tech support” told them to buy gold or silver, or to move their savings.
• A customer cashes out a retirement or investment account to buy metal and says they were told to hand it to a courier, or to have it picked up or shipped to someone else.
• A customer appears to be coached by someone on the line, is rushed, or cannot explain the purchase in their own words.
• A new romantic or online contact is directing the purchase.
• An older or vulnerable customer (NRS 200.5092) makes a purchase that is out of character or larger than their stated means.

When a red flag appears, the employee makes reasonable inquiries. The Compliance Officer then decides whether to proceed, pause, refuse or end the transaction. AWG does not tell anyone involved that a report has been or may be filed.

8. Reporting

Employees shall do all of the following:

1. Form 8300. Report cash received in one transaction, or in related transactions within 12 months, totaling more than $10,000, on IRS/FinCEN Form 8300 within 15 days (26 U.S.C. 6050I; 31 CFR 1027.330). “Cash” includes certain cashier’s checks, bank drafts, traveler’s checks and money orders of $10,000 or less. AWG e-files Form 8300 through the BSA E-Filing System, as required for filers of 10 or more information returns a year (26 CFR 301.6011-2). AWG gives the customer the required written statement by January 31 of the following year. AWG does not accept cash, so this should arise rarely.
2. Suspicious activity. Report suspicious transactions to the appropriate government authorities without delay. Dealers in precious metals are not required to file Suspicious Activity Reports (SARs), but AWG may file them voluntarily through the BSA E-Filing System. AWG uses any FinCEN key term that applies (for example, “FIN-2026-SCAMCENTERS”) and may check the “suspicious transaction” box on Form
3. Elder and vulnerable person exploitation. Report known or suspected exploitation of a person aged 60 or older, or of a vulnerable person, to Nevada Aging and Disability Services Division (Adult Protective Services) or to local law enforcement (NRS 200.5093). Good-faith reports are immune from civil and criminal liability (NRS 200.5096). AWG also follows the federal Interagency Statement on Elder Financial Exploitation (December 4, 2024) and may delay or decline a transaction where exploitation is suspected.
4. Sanctions. Report blocked or rejected transactions to OFAC within 10 business days (31 CFR 501.603 and 501.604).
5. IRS Form 1099-B. File where IRS broker reporting rules require it for AWG purchases of certain bullion from customers (26 U.S.C. 6045).

AWG shall at all times cooperate with and take guidance from FinCEN, the U.S. Department of the Treasury, the Internal Revenue Service, OFAC, the Nevada Attorney General, Nevada Consumer Affairs, the Las Vegas Metropolitan Police Department, and other appropriate regulatory and enforcement agencies.

9. Recordkeeping

Records are kept in a secure system, with access limited to those who need it. Records with personal information are protected and encrypted as Nevada law requires (NRS 603A.210 and 603A.215). They are destroyed securely when no longer needed (NRS 603A.200).

10. Designation of Compliance Officer

AWG designates the AWG Legal Team to serve as its Compliance Officer and AML Officer (31 CFR 1027.210(b)(2)). The Legal Team names one U.S.-based lead member who is accountable for the program. The Compliance Officer holds a position of responsibility, with the authority, independence and resources to carry out an effective program.

The Compliance Officer, along with senior management, is responsible for ensuring ongoing compliance with all federal and Nevada anti-money laundering laws and regulations. The Compliance Officer’s duties include:

• Ensuring the program is implemented effectively and its policies and procedures are followed.
• Updating the program as needed to reflect changes in the risk assessment, statutory requirements and further guidance from the Department of the Treasury.
• Ensuring appropriate personnel are trained in line with this policy.
• Ensuring reports are filed accurately and on time.
• Ensuring a periodic independent review of the program’s quality. The Compliance Officer may not conduct this review.

Compliance Officer: AWG Legal Team · Corporate@awg-us.com · 1-855-AWG-METL (1-855-294-6385) · 304 S. Jones Blvd., #7711, Las Vegas, NV 89107

11. Employee Training

Employee training is a key part of an effective compliance program (31 CFR 1027.210(b)(3)). Every employee, independent contractor and agent who deals with customers, payments or shipments must complete training before handling a transaction, and then at least once a year. Minimum training covers:

• How to identify suspicious activity and structured transactions, including the red flags in Section 7.
• Recordkeeping and reporting requirements.
• Verifying identification and screening against OFAC lists.
• Familiarity with federal and Nevada anti-money laundering laws.
• Recognizing elder financial exploitation and scams, and Nevada’s reporting rules (NRS 200.5093).
• The added rules for numismatic coin orders.

All employees must read this policy and sign the Acknowledgement of Employee Training. The acknowledgement is kept in their personnel file or in AWG’s AML files.

12. Independent Review

The USA PATRIOT Act and 31 CFR 1027.210(b)(4) require a precious metals dealer to have its compliance program independently tested. A senior-level AWG employee or another qualified party, such as AWG’s attorney or accountant, may conduct the review. The Compliance Officer, and anyone involved in running the program, cannot. The reviewer must be familiar with the program and with the AML requirements for a precious metals dealer.

The law does not set how often reviews happen. Instead, frequency must match the dealer’s assessment of its risks. AWG will complete its first independent review within 12 months of its first customer transaction and at least once a year after that. The reviewer reports findings in writing to senior management. The Compliance Officer tracks each finding until it is fixed.

13. Minimum Program Requirements (USA PATRIOT Act)

The USA PATRIOT Act requires every precious metals dealer to adopt a written AML program reasonably designed to ensure proper recordkeeping and reporting of certain transactions and to prevent the business from being used to launder money. At a minimum, the program must include:

1. Internal policies, procedures and controls based on the dealer’s assessment of its money laundering and terrorist financing risks, including policies for complying with the Bank Secrecy Act (31 U.S.C. 5311 et seq.). These must help identify transactions that may involve money laundering or terrorist financing. They must include reasonable inquiries to determine whether a transaction involves either, and procedures for refusing, withdrawing from or ending such transactions (Sections 4 to 9).
2. A designated Compliance Officer responsible for making sure policies and procedures are followed, procedures are updated, training is provided and reports are filed properly (Section 10).
3. An ongoing employee training program that explains policies and procedures and teaches how to identify suspicious activity (Section 11).
4. An independent review of the program, as frequent and thorough as the business’s risks require. An employee may perform it, but not the Compliance Officer (Section 12).

This program provides the information needed to comply with the USA PATRIOT Act.

14. Program Updates

On April 7, 2026, FinCEN proposed a rule to modernize AML/CFT program requirements for all covered financial institutions, including precious metals dealers. The proposal centers on a risk-based program with four parts: internal controls including risk assessment, independent testing, a U.S.-based compliance officer, and ongoing training. It also proposes a 12-month implementation period after any final rule. AWG’s program already follows that structure. The Compliance Officer will update this policy by the deadline of any final rule, and whenever FinCEN, OFAC or Nevada issues new requirements or guidance.

15. Contact

To report a concern about a transaction, or with questions about this policy, contact AWG’s Compliance Officer (AWG Legal Team):

• Email: Corporate@awg-us.com
• Phone: 1-855-AWG-METL (1-855-294-6385)
• Mail: 304 S. Jones Blvd., #7711, Las Vegas, NV 89107

Legal Authority

Federal: Bank Secrecy Act, 31 U.S.C. 5311 et seq.; USA PATRIOT Act Section 352, 31 U.S.C. 5318(h); 31 U.S.C. 5318(g) and 5318A; 31 CFR 1010.430; 31 CFR Part 1027 (including 1027.100, 1027.210 and 1027.330); 26 U.S.C. 6045 and 6050I; 26 CFR 301.6011-2; OFAC regulations, 31 CFR Part 501 (including 501.601, 501.603 and 501.604); FTC Telemarketing Sales Rule, 16 CFR 310.5; 22 U.S.C. 2371; FinCEN Alert FIN-2026-Alert005 (September 3, 2026); Interagency Statement on Elder Financial Exploitation (December 4, 2024); FinCEN proposed AML/CFT program rule (April 2026).

Nevada: NRS 207.195; NRS 200.5091 to 200.50995 (including 200.5092, 200.5093 and 200.5096); NRS 41.1395; NRS Chapter 599B (including 599B.080 to 599B.100 and 599B.270 to 599B.300); NRS Chapter 598; NRS 603A.200, 603A.210, 603A.215 and 603A.220.

Local: Clark County and City of Las Vegas business licensing for precious metals sales and purchases.