Our procedures for monitoring transactions, identifying unusual activity, and reporting suspicious matters.
Comfi Trading FZCO maintains transaction monitoring and reporting procedures designed to identify, review, and escalate unusual or potentially suspicious activity within its precious metals trading operations.
As a reporting entity in the precious metals sector, Comfi recognises the importance of monitoring customer activity, transaction patterns, payment methods, geographic exposure, and other risk indicators that may require further review. These procedures support the company’s wider AML/CFT framework and help ensure that trading activity remains transparent, traceable, and aligned with applicable regulatory obligations.
Comfi’s transaction monitoring approach includes:
- reviewing customer activity against expected profiles;
- identifying unusual or complex transactions;
- monitoring high-value or linked transactions;
- reviewing transactions involving higher-risk customers or jurisdictions;
- assessing unusual payment methods or third-party payments;
- screening customers and counterparties against relevant sanctions and watchlists;
- applying Customer Due Diligence and Enhanced Due Diligence where required;
- escalating concerns to the Compliance Officer;
- maintaining records of internal reviews and decisions;
- reporting suspicious matters through the appropriate regulatory channels where required.
Employees are expected to remain vigilant and to report unusual or potentially suspicious activity internally. The Compliance Officer is responsible for reviewing escalated matters, assessing available information, conducting further investigation where necessary, and determining whether external reporting is required.
Comfi also maintains strict confidentiality standards. Employees must not inform customers or third parties that a transaction is being reviewed, investigated, escalated, or reported. This supports the integrity of the reporting process and helps protect ongoing compliance reviews.
Where a transaction or customer relationship presents a level of risk that cannot be adequately understood or mitigated, Comfi may decide to hold, decline, or terminate the transaction or business relationship in accordance with its internal procedures and applicable requirements.
Through its transaction monitoring and reporting framework, Comfi Trading FZCO reinforces its commitment to responsible bullion trading, effective risk management, and a strong culture of compliance.