Legal
Anti-Money-Laundering (AML) Policy
1. Our commitment
LAZARO DAVINCHY buys gold and other precious-metal items and is committed to preventing our business from being used to launder money or finance illegal activity. We maintain this Anti-Money-Laundering ("AML") program consistent with applicable U.S. federal law (including the Bank Secrecy Act and related rules for dealers in precious metals, precious stones, and jewels), the State of Florida's secondhand-dealer and precious-metals requirements, and local Miami-Dade ordinances. [Confirm exact applicable thresholds and filing obligations with counsel/compliance.]
2. Customer identification ("Know Your Customer")
Before completing a purchase, we may verify your identity by collecting and recording:
- Full legal name, date of birth, and current address;
- A valid government-issued photo ID (e.g., driver's license, state ID, or passport); and
- Confirmation that you are the lawful owner of the items and have the right to sell them.
We may decline or pause any transaction if we cannot verify identity or ownership, or if the transaction appears suspicious.
3. Recordkeeping
We retain transaction records — including customer identification, item descriptions, weights, purity, photographs, offer amounts, and payment details — for at least the period required by applicable law [insert retention period, e.g., 5 years]. Records are stored securely and made available to law enforcement and regulators as required.
4. Reporting and holding periods
We comply with applicable reporting requirements, including any required reporting of cash transactions and the filing of suspicious-activity reports where warranted. Where local law imposes a holding period or requires reporting purchased items to law-enforcement databases (such as a secondhand-dealer reporting system), we observe those requirements before items are resold or refined. [Confirm Miami-Dade / Florida holding and reporting specifics with counsel.]
5. Payments
We pay by traceable methods (PayPal, Venmo, Zelle, or another agreed method). We do not structure transactions to evade reporting thresholds, and we will not knowingly facilitate any attempt to do so.
6. Prohibited and suspicious activity
We will not purchase items we reasonably believe to be stolen, fraudulently obtained, or connected to illegal activity. Indicators that may trigger additional review include refusal to provide identification, inconsistent ownership information, or unusual transaction patterns. We cooperate fully with law enforcement.
7. Stolen-property protection
If items are later determined to be stolen, we cooperate with authorities and follow all legal requirements regarding recovery and return. Customers warrant lawful ownership at the time of sale and remain responsible for any misrepresentation.
8. Training and oversight
[Designate an AML compliance officer and describe staff training cadence — confirm with counsel.] Our personnel are instructed to follow these procedures and to escalate suspicious activity to the compliance officer.
9. Updates
We review and update this Policy as laws and our operations change. The "Effective date" reflects the current version.
10. Contact
AML inquiries: support@lazarogold.com · (305) 372-1585 · LAZARO DAVINCHY, Seybold Building, 1st Floor / Suite 130, Miami, FL.