Anti-Money Laundering Policy

1.Purpose and Scope

This AML Policy establishes the framework through which the Company seeks to detect and prevent money laundering, terrorist financing, and related financial crimes. The Company's business activities include direct-to-consumer sales of physical precious metals and the facilitation of precious metals purchased in connection with self-directed IRAs, coordinated with IRS-approved custodians. This Policy applies to all officers, employees, contractors, and agents of Ardent Gold LLC who are involved in customer onboarding, sales, payments, fulfillment, account management, or transaction processing. Every such person is expected to understand and adhere to this Policy in the course of their duties.

2.Regulatory Applicability

Ardent Gold LLC operates as a dealer in precious metals, as defined under 31 CFR § 1027, and maintains an AML Program reasonably designed to prevent the Company from being used to facilitate money laundering or terrorist financing. In connection with precious metals IRA transactions, the Company acts as a precious metals dealer and facilitator, and not as a custodian, trustee, or tax advisor. Regulatory obligations specific to custodial services remain the responsibility of the applicable IRS-approved custodian or trustee, who maintains its own compliance program.

3.AML Compliance Officer

The Company has designated an AML Compliance Officer who is responsible for the implementation, oversight, and ongoing maintenance of this AML Program. The responsibilities of the AML Compliance Officer include the following:

• administering the Company's AML policies and procedures;
• monitoring the Company's compliance with applicable laws and regulations;
• reviewing and escalating suspicious activity as appropriate;
• overseeing AML training for relevant personnel; and
• serving as the primary point of contact for regulators and law enforcement.

Designated AML Compliance Officer:

Name: Aaron Jensen
Title: President
Email: team@ardentgold.co

4.Customer Identification and Due Diligence

4.1 Customer Identification Program (CIP)

The Company obtains and verifies identifying information for customers prior to completing covered transactions, consistent with the nature of the transaction and the applicable level of risk. Customer information may include the customer's full legal name; residential or business address; date of birth for individuals; government-issued photo identification; and entity formation documents for business customers. Verification may be performed using documentary methods, reasonable non-documentary methods, or a combination of both. For precious metals IRA transactions, customer identification may be performed directly by the Company and/or in coordination with IRS-approved custodians or trustees.

4.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to higher-risk customers or transactions. Circumstances that may warrant Enhanced Due Diligence include high-dollar or unusually complex transactions; repeated or potentially structured transactions; Politically Exposed Persons (PEPs); transactions involving high-risk jurisdictions; and unusual payment methods or payments involving third parties. Enhanced Due Diligence measures may include obtaining additional documentation, making source-of-funds inquiries, and conducting heightened review of the relevant transactions.

5.Transaction Monitoring and Red Flags

The Company monitors transactions for indicators of potentially suspicious activity. Such indicators include, among others: attempts to structure transactions in order to avoid applicable reporting thresholds; requests for anonymity or a refusal to provide identifying information; payments made from unrelated or undisclosed third parties; the rapid buying, selling, or liquidation of precious metals without a clear economic purpose; and activity that is unusual or inconsistent with a customer's known profile. Employees are required to promptly report any suspicious activity to the AML Compliance Officer.

6.Reporting Requirements

6.1 Currency Transaction Reporting

The Company complies with applicable cash transaction reporting requirements, including the filing of IRS Form 8300 when required by law.

6.2 Suspicious Activity Reporting

When appropriate, the Company will report suspicious activity in accordance with FinCEN guidance and applicable regulations. Employees are strictly prohibited from disclosing the existence of any suspicious activity report or related investigation to customers or any third party, a practice commonly known as "tipping off."

7.Recordkeeping

The Company maintains records related to customer identification and due diligence, transaction history, AML reviews and escalations, and employee training. These records are retained for a minimum of five (5) years, or for a longer period where required by applicable law or regulation.

8.Employee Training

Employees who are involved in sales, payments, customer onboarding, fulfillment, or compliance receive AML training at least annually. This training covers an overview of applicable AML laws and obligations, the identification of red flags, internal escalation procedures, and confidentiality and non-retaliation requirements. Training records are maintained by the AML Compliance Officer.

9.Independent Review

The Company periodically reviews its AML Program in order to assess its effectiveness and its compliance with applicable requirements. These reviews may be conducted internally or by qualified third parties, as appropriate.

10.Confidentiality and Non-Retaliation

Employees who report suspicious activity in good faith are protected from retaliation. All AML-related reviews, investigations, and reports are handled on a confidential basis and are shared only with those who have a legitimate need to know.

11.Policy Enforcement

Failure to comply with this AML Policy may result in disciplinary action, up to and including termination of employment or engagement. Non-compliance may also expose individuals to civil or criminal liability under applicable law.

12.Policy Approval

This AML Policy has been reviewed and approved by the senior management of Ardent Gold LLC.