AML Information for Clients

Baumann Group a.s., operator of the GOLDU® brand, is an obliged entity under Act No. 253/2008 Coll., on certain measures against the legalisation of proceeds of crime and the financing of terrorism (the AML Act). The aim of these measures is to protect clients, ensure the transparency of transactions and consistently comply with the laws of the Czech Republic and the European Union.

1. Client Identification and Control

1.1 Scope of identification and control

In accordance with AML legislation, when buying, selling or having precious metals bought back, the client may in particular be asked to:

present a valid identity document, for example an identity card or passport,
verify personal data and prove the address of permanent or temporary residence,
verify the beneficial owner or the authorisation to represent a legal entity,
verify the ownership and control structure of a legal entity,
provide additional information on the purpose and nature of the transaction,
prove the origin of the funds or assets,
be checked against politically exposed persons (PEP) databases,
be checked against sanctions lists,
be checked in public registers,
be checked in other databases used to fulfil AML obligations.

1.2 Client's duty to cooperate

Without fulfilment of the statutory obligations and without the necessary cooperation of the client, the transaction cannot be carried out. If the client fails to provide the requested information, fails to submit the required documents or fails to provide other necessary cooperation, GOLDU is entitled to refuse the transaction, suspend its execution or terminate the business relationship in accordance with the law and internal risk-management rules.

2. Verification of the Origin of Funds and Assets

2.1 Proof of the origin of funds and assets

In cases stipulated by law or on the basis of an internal risk assessment, GOLDU requires information or documents proving the origin of the funds used to purchase investment gold, investment silver or other precious metals. In justified cases, GOLDU may also require information or documents relating to the broader origin of the client's assets, where this is necessary to fulfil AML obligations or to assess the risk of the transaction.

2.2 Examples of relevant proof

Relevant proof may in particular include:

a bank account statement,
proof of taxable income from employment or business activity,
a tax return or other tax documents,
a contract for the sale of assets, for example real estate, a vehicle or a business share,
a final decision from inheritance proceedings,
a gift contract,
accounting documents,
other official documents proving the legal origin of the funds or assets.

2.3 Purpose of processing this information

This information is requested and processed solely to the extent necessary to fulfil statutory AML obligations, maintain statutory records, assess the risk of the transaction and protect the legitimate interests of Baumann Group a.s. GOLDU is entitled to require proof of the origin of funds or assets repeatedly, where required by AML legislation, the nature of the transaction, a change of circumstances or the internal risk assessment.

3. Politically Exposed Persons (PEP) and International Sanctions

3.1 Increased attention for high-risk transactions

Baumann Group a.s. pays particular attention to transactions that present an increased risk. This concerns in particular:

politically exposed persons (PEP) within the meaning of the AML Act,
persons listed on international sanctions lists,
persons linked to a sanctioned person or sanctioned company,
clients from high-risk countries,
clients with a complex or non-transparent ownership structure,
clients who present an increased AML, sanctions, security or reputational risk.

3.2 Enhanced identification and control

In certain circumstances, enhanced identification and control may be carried out in respect of the client in accordance with the AML Act. In justified cases, GOLDU reserves the right to require additional documentation, additional verification of the client, proof of the origin of funds or assets, or to refuse the transaction.

3.3 Sanctions screening

GOLDU is entitled to screen clients, beneficial owners, persons authorised to represent the client and other relevant persons against sanctions lists and databases used to fulfil statutory obligations. If the client, the beneficial owner or another relevant person is listed on a sanctions list, or there is a suspicion of a link to a sanctioned person or sanctioned company, GOLDU is entitled to refuse or suspend the transaction or to proceed in accordance with the law and internal risk-management rules.

4. Protection of Personal Data and GDPR

4.1 Confidentiality and protection of data

All collected personal and identification data is processed confidentially and in accordance with applicable legal regulations, in particular:

Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR),
Act No. 253/2008 Coll.,
other legal regulations on the protection of personal data.

4.2 Scope of use of personal data

We use personal data only to the extent necessary to fulfil statutory obligations, fulfil contractual obligations, maintain statutory records, protect the legitimate interests of the company and fulfil AML/KYC obligations. Detailed information is provided in the Privacy Policy (GDPR) published on the GOLDU website.

5. Reasons for Refusing a Transaction

5.1 Situations in which a transaction may be refused

GOLDU reserves the right to refuse to carry out a transaction, suspend its processing or terminate the business relationship, in particular in the following cases:

the client does not provide the necessary cooperation in identification or control,
the client does not provide the requested information or submit the required documents,
the identity of the client, the beneficial owner or the person authorised to represent the client cannot be reliably verified,
the origin of the funds or assets cannot be verified,
there is a reasonable suspicion of a breach of AML regulations or of the legalisation of proceeds of crime,
the client is listed on a sanctions list or there is a suspicion of a link to a sanctioned person or sanctioned company,
the transaction has unusual, non-standard or particularly high-risk features,
the transaction presents a disproportionate AML, sanctions, security, reputational or legal risk to the company.

5.2 Refusal of a transaction on AML or risk-management grounds

GOLDU is also entitled to refuse to carry out a transaction where communicating a specific reason could conflict with legal regulations, internal risk-management rules or the company's obligations in the area of AML. In certain cases, the company may not be entitled to inform the client of the specific reason for the refusal or further course of action, where doing so could breach legal regulations or AML obligations.

6. Related Documents

This AML information forms part of the contractual and information framework of Baumann Group a.s. and the GOLDU® brand. Related documents are in particular:

General Terms and Conditions,
Delivery and Payment Terms,
Buy-back Conditions,
Privacy Policy (GDPR),
Cookie Policy,
Notice of risks associated with investing in precious metals.

7. Final Provisions

7.1 Updating of the document

This AML information may be updated on an ongoing basis, in particular in connection with changes to the legal regulations of the Czech Republic, the European Union or the internal procedures of Baumann Group a.s.

7.2 Current version of the document

The current and valid version of the document is always available on the official website of GOLDU.

7.3 Governing law and language

This AML information is governed by the law of the Czech Republic. The governing language of this document is Czech; in the event of any discrepancy between language versions, the Czech version prevails.

7.4 Effectiveness of the document

This AML information takes effect on 28 May 2026.

8. Company Identification

Baumann Group a.s., operator of the GOLDU® brand

Registered office: Vyskočilova 1481/4, 140 00 Praha 4, Czech Republic
Company ID (IČO): 22263284
VAT ID (DIČ): CZ22263284
Commercial Register: Municipal Court in Prague, Section B, Insert 29197
Web: www.goldu.cz
Data box: xtps2mn
E-mail: info@goldu.eu
Phone: +420 601 359 200