Compliance Framework

Anti-Money Laundering (AML) Policy

Compliance. Transparency. Responsible Global Trade.

Etalery is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in global diamond and jewellery sourcing.

This Anti-Money Laundering (AML) Policy establishes the principles, controls, and procedures designed to prevent the misuse of the Etalery platform for money laundering, terrorist financing, or other illicit financial activities.

This policy applies to Etalery, its directors, officers, employees, contractors, consortium partners, suppliers, buyers, and all participants within the Etalery ecosystem.

1

Policy Objective

  • Prevent platform misuse for money laundering or financial crime
  • Ensure compliance with applicable AML laws and international standards
  • Establish robust customer due diligence and monitoring
  • Protect the integrity of global diamond and jewellery trade

Etalery adopts a risk-based approach proportionate to its operations.

2

Regulatory Alignment

  • Global AML and Counter-Terrorist Financing (CTF) principles
  • Financial Action Task Force (FATF) recommendations
  • Applicable national and regional AML laws
  • Trade-related compliance requirements
3

Risk-Based Approach

Etalery assesses risk by considering customer nature, geography, transaction type, and product characteristics.

4

Customer Due Diligence (CDD)

  • Business identity verification (KYB)
  • Individual identity verification (KYC)
  • Ownership and control structure review
  • Screening against sanctions and watchlists
5

Enhanced Due Diligence (EDD)

Applied for high-risk jurisdictions, complex structures, or unusual patterns.

6

Ongoing Monitoring

Continuous review of transaction patterns and consistency checks between profiles and activity.

7

Suspicious Activity Reporting

Zero-tolerance approach. Suspicious behavior is escalated, reviewed, and reported to authorities where required.

8

Prohibited Activities

  • Concealing illicit funds
  • Engaging with sanctioned entities
  • Evading reporting requirements
  • Misrepresentation of identity
9

Record Keeping

Retention of identification, due diligence, and transaction records for legally required periods.

10

Training & Awareness

Relevant personnel receive AML compliance training to promote a culture of accountability.

11

Governance & Oversight

AML compliance is overseen at a senior level, including policy updates and risk assessment.

12

Enforcement & Disciplinary Action

Violations may result in termination of access, contractual remedies, or legal action.

13

Policy Review & Updates

Periodically reviewed to reflect changes in laws, evolving risks, and industry best practices.

Our Commitment

Etalery is committed to operating a sourcing ecosystem where transparency, accountability, and lawful conduct are fundamental.

We believe that effective AML controls are essential to protecting institutional buyers, ethical manufacturers, and the integrity of global diamond and jewellery trade.

Compliance-First.Transparent.Responsible Global Trade.