AML Policy

Anti-Money Laundering Policy & Know Your Counterparty Policy and Procedure

Passion Art Jewelry (HK) Limited acknowledges the importance of preventing money laundering, terrorist financing, proliferation financing, tax evasion, and sanction violation. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan, or engage in terrorism.

To safeguard the Passion Art Jewelry (HK) Limited against the previously mentioned risks, Passion Art Jewelry (HK) Limited has established this Anti-Money Laundering (“AML”) Policy to ensure timely risk identification and establishment of appropriate controls to mitigate the above risks.

This policy confirms Passion Art Jewelry (HK) Limited’s commitment to prevent money-laundering and the financing of terrorism in its business practices and transactions by complying with the relevant laws and regulations.

KYC Procedure

Passion Art Jewelry (HK) Limited has established Know Your Counterparty (KYC) procedures to combat money laundering and the financing of terrorism. These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity. Passion Art Jewelry (HK) Limited commits to review our KYC policy and procedure every year and make revisions as needed.

By collecting and reviewing the information in completed KYC forms, Passion Art Jewelry (HK) Limited commits to

  • establishing the identity of our counterparties

  • maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses

  • checking that our counterparties are not considered high-risk (this means checking whether counterparties are based in FATF high-risk jurisdictions, named on government-sponsored watchlists or international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRAs))

  • maintaining KYC records for seven years after the date of each transaction

  • maintaining records of all single or linked cash (or cash-like) transactions above 10,000 USD

  • monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.

If counterparties are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:

  • Cease trading with the counterparty

  • Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watchlists or sanctions list

After the establishment of a business relationship, ongoing monitoring must be performed on the counterparties’ profiles to understand the counterparties’ activities, update the knowledge of the counterparties and detect potentially unusual or suspicious activities.

AML Officer

Passion Art Jewelry (HK) Limited appointed AML Officer is responsible for the development and implementation of this policy and relevant procedures.

The AML officer shall maintain KYC records and records of any suspicious activity.

Periodic review of transactions enables Passion Art Jewelry (HK) Limited to identify or detect any anomalies in the transactions, potential suspicious activities, trends or patterns. Transaction reviews in respect of customers and counterparties will be carried out on an annual basis by the AML officer.

AML officer commits to review our KYC policy and procedure every year and make revisions as needed.

AML Policy Awareness

Passion Art Jewelry (HK) Limited will provide regular training to all members of staff to ensure they understand and comply with the company’s AML Policy and relevant procedures.

Meetings will be held on an as-needed basis to ensure that appropriate information regarding money laundering, terrorism financing and sanctions risks is communicated to relevant staff in a timely manner so that they are equipped with adequate information about the latest developments to make informed decisions to manage these risks.

Reporting Procedure

Passion Art Jewelry (HK) Limited has the obligation to report any knowledge of money laundering to the relevant regulatory bodies and law enforcement agencies.

The company also has an internal reporting process to ensure identification and reporting of suspicious activities, relationships or transactions. When suspicion or knowledge arises of money laundering or terrorism financing, it must be internally reported to the AML officer. The AML officer will investigate further and discuss their findings and remedial action with senior management.

In regards to external reporting, the AML officer will determine the severity of the situation and report to regulatory bodies and law enforcement accordingly, acting as the point of contact.

Date: 10/05/2026

If you have any questions regarding our AML policy, please do not hesitate to contact us for further information.