AML POLICY

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ANTI-MONEY LAUNDERING POLICY (AML POLICY)

ZULI JEWELRY

1. Introduction

ZULI Jewelry, based in the Netherlands, designs and produces unique gemstone jewelry. We collaborate with female artisans in Afghanistan, providing them with opportunities for independent income. This policy is established to comply with the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (WWFT) and the European AML directives. The aim is to prevent money laundering, fraud, and terrorist financing.

2. Scope

This policy applies to all customers, suppliers, employees, and partners of ZULI Jewelry, both in the Netherlands and abroad. It covers all transactions, including online sales and participation in international trade shows.

3. Legal Framework

ZULI Jewelry complies with the obligations set out in the WWFT and relevant European directives (AMLD5 and AMLD6). The company performs customer due diligence (CDD) and monitors transactions to detect suspicious activities.

4. Risk Assessment

The trade in gemstones and international transactions carry an increased risk of money laundering. ZULI Jewelry applies a risk-based approach, assessing customers, suppliers, and transactions based on geographic, business, and behavioral factors.

5. Customer Due Diligence (CDD)

ZULI Jewelry verifies the identity of customers for each transaction above the legal threshold and gathers information about the source of funds. If there are indications of suspicious activity, the transaction will be blocked and reported to FIU-Netherlands.

6. Reporting to FIU-Netherlands

All ZULI Jewelry employees are required to immediately report any suspected money laundering or fraudulent activities to the compliance officer. The compliance officer is responsible for filing the report with FIU-Netherlands in accordance with legal procedures.

7. Training & Awareness

ZULI Jewelry employees receive regular training on WWFT compliance, recognizing suspicious transactions, and maintaining ethical business practices within the jewelry and gemstone industry.

8. Data Protection & Retention

All customer data is securely stored in accordance with the GDPR and the WWFT. Relevant documents and transaction data are retained for at least five years.

9. Final Provision

This AML policy comes into effect on October 7, 2025, and will be reviewed annually. ZULI Jewelry is committed to integrity, transparency, and responsible business conduct within the international jewelry trade.

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Kvk nummer: 93387784

BTW nummer: NL866375806B01

Kantoor : Zuli, Eemplein 88 te Amersfoort


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