Anti-Money Laundering (AML) Compliance Policy

Frangroup, LLC (“Company”) is committed to conducting its precious metals and numismatic business in a lawful and responsible manner and to preventing its business, products, accounts, and transactions from being used for money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful activity.

The Company maintains this Anti-Money Laundering (“AML”) Policy as a risk based compliance program appropriate to the nature and size of its business.

The Company will comply with applicable federal, state, and local laws and regulations concerning anti money laundering, financial crime prevention, recordkeeping, sanctions, and cash transaction reporting.

The Company purchases and resells precious metals, bullion, coins, numismatic products, and related merchandise through approved vendors, wholesalers, online marketplaces, live commerce platforms, and other lawful sales channels.

Whenever practicable, inventory is acquired from established wholesalers, refiners, mints, distributors, dealers, and other identifiable commercial sources.

The Company designates the following individual as the person responsible for administration of this policy:

AML Compliance Officer: Dennis Bok
Title: Agent

The AML Compliance Officer is responsible for:

• •Maintaining and implementing this policy
• •Evaluating transactions presenting heightened AML risk
• •Maintaining appropriate records
• •Reviewing suspicious or unusual activity
• •Ensuring required reports are made when applicable
• •Monitoring changes in applicable AML requirements
• •Periodically reviewing and updating the Company's AML procedures

The Company evaluates money laundering and financial crime risk based on relevant circumstances, including:

• •The nature and value of the transaction
• •The customer's or supplier's identity and location
• •The method of payment
• •The source of inventory
• •Transaction frequency and pattern
• •Unusual or commercially unreasonable activity
• •Transactions involving high risk jurisdictions
• •Attempts to conceal ownership, identity, source of funds, or source of merchandise
• •Other circumstances reasonably indicating heightened risk

Transactions presenting elevated risk may be delayed, declined, cancelled, or subjected to additional verification.

The Company may obtain and verify identifying information when appropriate based upon the nature, value, method, or risk of a transaction.

Information requested may include:

• •Full legal name
• •Billing and shipping address
• •Telephone number and email address
• •Government issued identification
• •Business name and organizational information
• •Payment information
• •Other information reasonably necessary to verify identity or transaction legitimacy

The Company will not knowingly conduct transactions using false identities or obviously fraudulent documentation.

The Company seeks to purchase inventory from legitimate and identifiable sources.

Supplier due diligence may include verification of:

• •Legal or business name
• •Physical or business address
• •Website and contact information
• •Dealer or reseller credentials
• •Tax or resale documentation
• •Commercial reputation
• •Invoices and purchase records
• •Other information appropriate to the relationship

The Company may decline transactions involving merchandise of suspicious, unknown, or inadequately documented origin.

The Company will pay particular attention to transactions or conduct that appear inconsistent with legitimate business activity.

Potential red flags include, but are not limited to:

• •Attempts to avoid identification or recordkeeping requirements
• •Attempts to structure transactions into smaller amounts to avoid reporting thresholds
• •Large or unusual cash payments
• •Payments from unrelated third parties without a reasonable explanation
• •Multiple payment methods used to obscure the source of funds
• •Requests to ship merchandise to unrelated or unexplained third parties
• •Transactions materially inconsistent with a customer's known activity
• •Unexplained urgency or willingness to pay substantially above market value
• •Suspected stolen, fraudulent, counterfeit, or unlawfully obtained merchandise
• •Transactions connected with sanctioned persons or jurisdictions
• •Any conduct reasonably suggesting money laundering, fraud, terrorist financing, or sanctions evasion

The Company reserves the right to refuse, cancel, or terminate any transaction or business relationship presenting unacceptable compliance risk.

The Company discourages large cash transactions.

Where applicable, the Company will comply with federal reporting requirements applicable to receipt of cash exceeding applicable thresholds, including filing IRS/FinCEN Form 8300 when legally required.

The Company will not knowingly assist a customer in structuring transactions to avoid cash reporting requirements.

The Company will not knowingly conduct business with persons or entities prohibited under applicable United States economic sanctions.

When appropriate based upon transaction risk, the Company may screen customers, suppliers, beneficial owners, or counterparties against sanctions and restricted party information maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and other applicable government authorities.

The Company will maintain commercially reasonable records relating to purchases and sales, including as applicable:

• •Purchase invoices
• •Sales receipts
• •Payment records
• •Shipping records
• •Supplier information
• •Customer information
• •Identification records when collected
• •Records relating to unusual or suspicious transactions

Records will be retained for the period required by applicable law and the Company’s normal business and accounting practices.

For transactions conducted through established third party platforms, payment processors, or marketplaces, the Company may rely in part on identity verification, fraud prevention, payment controls, transaction records, and compliance procedures implemented by those platforms.

The Company nevertheless retains the right to perform additional verification or decline transactions presenting heightened risk.

Any employees or representatives involved in purchasing, sales, payments, fulfillment, or customer service will receive AML guidance appropriate to their responsibilities.

Training may include recognition of suspicious transaction patterns, fraud indicators, cash reporting requirements, sanctions concerns, escalation procedures, and Company recordkeeping requirements.

Suspected AML violations or suspicious activity must be referred to the AML Compliance Officer.

Depending upon the circumstances, the Company may:

• •Request additional identification or documentation
• •Place a transaction on hold
• •Decline or cancel a transaction
• •Terminate a customer or supplier relationship
• •Preserve relevant transaction records
• •Make reports to governmental authorities when required by applicable law

This AML Policy will be periodically reviewed to ensure that it remains appropriate for the Company’s size, transaction volume, business model, products, customer base, suppliers, and applicable legal requirements.

The Company may revise this policy as necessary in response to changes in its business or applicable law.