1. Introduction

COMEX Alert is committed to conducting its business lawfully, ethically and transparently.

This Anti-Money Laundering Policy explains the measures used by COMEXAlert.com to reduce the risk that its website, subscriptions, payment systems, Telegram channels, WhatsApp communities or related services are used for:

  • Money laundering;
  • Terrorist financing;
  • Fraud;
  • Sanctions evasion;
  • Identity theft;
  • Payment abuse;
  • Proliferation financing; or
  • Other unlawful financial activity.

This Policy should be read together with our Terms & Conditions, Privacy Policy, Risk Disclaimer and any other policies published on COMEXAlert.com.

2. About COMEX Alert

COMEX Alert provides general commodity-market information, educational content and trading-signal subscription services relating to instruments such as Gold, Silver, Copper, Crude Oil, Natural Gas and other financial markets.

COMEX Alert is not a bank, broker, exchange, investment manager, money-transfer service or cryptocurrency exchange.

Unless expressly stated otherwise, COMEX Alert does not:

  • Hold customer trading funds;
  • Accept deposits for investment;
  • Execute trades on behalf of users;
  • Manage customer brokerage accounts;
  • Transfer funds between customers;
  • Provide custodial wallet services; or
  • Receive a share of customer trading capital.

Payments made to COMEX Alert are payments for access to its digital content, subscriptions or related services.

3. Purpose of This Policy

The purpose of this Policy is to establish a reasonable and proportionate framework for:

  • Identifying users where appropriate;
  • Assessing customer, payment and geographic risks;
  • Detecting unusual or suspicious activity;
  • Preventing prohibited transactions;
  • Screening against applicable sanctions restrictions;
  • Maintaining appropriate records;
  • Cooperating with payment providers and competent authorities; and
  • Protecting COMEX Alert and its users from financial crime.

The measures applied may vary according to the level of risk presented by a user, transaction, payment method or jurisdiction.

4. Applicable Laws

COMEX Alert intends to comply with anti-money laundering, counter-terrorist financing, sanctions, fraud-prevention and financial-crime laws that apply to its business in [insert country or legal jurisdiction].

Because COMEX Alert may serve users in different countries, additional restrictions may apply depending on:

  • The user’s country of residence;
  • The location from which the service is accessed;
  • The payment method used;
  • The payment provider involved; and
  • Applicable international sanctions.

COMEX Alert may apply stricter controls where reasonably necessary, even where those controls are not expressly required by local law.

5. Risk-Based Approach

COMEX Alert applies a risk-based approach to financial-crime prevention.

We may consider factors including:

  • A user’s location or nationality;
  • The billing country;
  • The source and destination of a payment;
  • The payment method;
  • The value and frequency of transactions;
  • Differences between customer and payment information;
  • Use of third-party payment accounts;
  • Unusual refund or chargeback behaviour;
  • Attempts to hide identity or location;
  • Use of anonymising technologies;
  • Sanctions exposure;
  • Politically exposed person status;
  • Adverse or suspicious information;
  • The nature of a business customer; and
  • Any other factor reasonably indicating increased risk.

Users or transactions assessed as presenting a higher risk may be subject to enhanced checks, restrictions, delays or rejection.

6. Customer Identification and Verification

COMEX Alert may request information necessary to identify or verify a user before or after providing access to a service.

Information requested may include:

  • Full legal name;
  • Date of birth;
  • Residential or business address;
  • Country of residence;
  • Nationality;
  • Email address;
  • Telephone number;
  • Telegram or WhatsApp account details;
  • Government-issued identification;
  • Proof of address;
  • Payment information;
  • Occupation or business activity;
  • Source of funds;
  • Reason for purchasing the service; and
  • Any other information reasonably required for compliance purposes.

Identity verification may be requested when:

  • A transaction is unusually large or complex;
  • Multiple or linked payments are identified;
  • Payment details do not match customer information;
  • A payment is made by an unrelated third party;
  • Fraud or identity theft is suspected;
  • A user requests repeated or unusual refunds;
  • A user is connected to a higher-risk jurisdiction;
  • Sanctions or politically exposed person screening produces a potential match;
  • Information supplied appears inaccurate or inconsistent; or
  • Verification is required by law or by a payment provider.

COMEX Alert may decline to provide access until requested information has been satisfactorily verified.

7. Business Customers and Beneficial Ownership

Where a subscription or service is purchased by a company, partnership, trust or other legal entity, COMEX Alert may request:

  • The entity’s registered name;
  • Registration or incorporation number;
  • Registered address;
  • Nature of business;
  • Names of directors, partners or trustees;
  • Ownership and control structure;
  • Details of the person acting on behalf of the entity;
  • Evidence that the representative is authorised to act; and
  • Information identifying the ultimate beneficial owner.

An ultimate beneficial owner is generally the individual who ultimately owns, controls or benefits from the entity or transaction.

COMEX Alert may reject an application where ownership or control cannot be reasonably established.

8. Enhanced Due Diligence

Additional checks may be applied where a customer or transaction presents a higher risk.

Enhanced due diligence may include:

  • Requesting additional identification documents;
  • Verifying information using independent sources;
  • Obtaining information about employment or business activity;
  • Establishing the source of funds;
  • Establishing the source of wealth where appropriate;
  • Confirming the purpose of the transaction;
  • Requiring payment from an account held in the customer’s own name;
  • Requesting information about beneficial ownership;
  • Obtaining management approval before providing access;
  • Applying increased transaction monitoring; or
  • Limiting the payment methods available.

Failure to provide reasonably requested information may result in the transaction being rejected or the service being suspended.

9. Politically Exposed Persons

A politically exposed person, or PEP, is an individual who holds or has held a prominent public position, as well as certain family members and close associates of that individual.

PEP status does not automatically prevent a person from using COMEX Alert. However, a PEP or related person may be subject to additional checks, including:

  • Verification of identity;
  • Establishing source of funds;
  • Establishing source of wealth where appropriate;
  • Senior approval;
  • Additional sanctions screening; and
  • Enhanced ongoing monitoring.

COMEX Alert may refuse or terminate a relationship where the financial-crime risk cannot be reasonably managed.

10. Sanctions Compliance

COMEX Alert does not knowingly provide services or make funds available to persons, entities, organisations or jurisdictions subject to applicable sanctions or asset-freezing restrictions.

Screening may be conducted against relevant sanctions lists, which may include lists maintained by:

  • The United Nations;
  • Authorities in COMEX Alert’s country of registration;
  • The United Kingdom;
  • The European Union;
  • The United States Office of Foreign Assets Control; and
  • Other competent authorities applicable to the transaction.

COMEX Alert may block, delay, reject, suspend or cancel a transaction where:

  • A sanctions match is identified;
  • A user attempts to avoid geographic restrictions;
  • A transaction may involve a sanctioned person or entity;
  • The payment provider rejects the transaction for sanctions reasons; or
  • Further investigation is reasonably required.

COMEX Alert is not required to complete a transaction that may violate applicable sanctions.

11. Payment Controls

Payments should normally be made using a payment method lawfully owned or controlled by the person purchasing the service.

COMEX Alert may reject or investigate:

  • Payments made using stolen or unauthorised cards;
  • Payments from unrelated third parties;
  • Payments using false customer details;
  • Multiple failed payment attempts;
  • Unusual payment splitting;
  • Payments followed by immediate refund requests;
  • Repeated chargebacks;
  • Payments from prohibited jurisdictions;
  • Payments involving suspicious intermediaries;
  • Transactions that appear inconsistent with the service purchased; or
  • Transactions rejected or flagged by a payment provider.

COMEX Alert does not normally accept physical cash.

Where cryptocurrency or another digital asset payment is offered, COMEX Alert may request additional information concerning the wallet owner, transaction source, source of funds or purpose of payment.

12. Prohibited Activities

Users must not use COMEX Alert or its payment systems to:

  • Launder proceeds of crime;
  • Finance terrorism or prohibited organisations;
  • Evade sanctions;
  • Conceal the source or ownership of funds;
  • Make payments for another person without authorisation;
  • Use stolen payment information;
  • Commit refund or chargeback fraud;
  • Use false identification;
  • Create accounts using another person’s identity;
  • Purchase access for unlawful resale;
  • Transfer value between unrelated parties;
  • Circumvent payment-provider restrictions;
  • Avoid customer-verification requirements;
  • Divide transactions to avoid compliance checks; or
  • Conduct any activity prohibited by applicable law.

COMEX Alert may immediately suspend or terminate access where prohibited activity is suspected.

13. Monitoring and Suspicious Activity

COMEX Alert may monitor account, subscription and payment activity to identify suspicious or unusual behaviour.

Indicators may include:

  • Information that is false, inconsistent or difficult to verify;
  • A user refusing to provide basic identification information;
  • Payment details that do not match the purchaser;
  • Frequent changes in name, location or account information;
  • Numerous transactions using different payment methods;
  • Repeated failed payments;
  • Multiple purchases followed by refund requests;
  • Unusual chargeback activity;
  • Transactions from high-risk or sanctioned locations;
  • Attempts to bypass geographic restrictions;
  • Use of multiple accounts for the same person;
  • Unexplained use of intermediaries;
  • Requests to send refunds to a different payment method;
  • Threats intended to avoid verification; or
  • Any behaviour reasonably connected to fraud or financial crime.

The presence of an indicator does not automatically prove unlawful conduct. COMEX Alert will assess the available circumstances before deciding what action is appropriate.

14. Action Taken on Suspicious Activity

Where COMEX Alert identifies potentially suspicious activity, it may:

  • Request additional information;
  • Delay processing;
  • Reject a payment;
  • Decline a refund to an unrelated payment method;
  • Restrict or suspend an account;
  • Remove access to premium services;
  • Cancel a subscription;
  • Preserve relevant records;
  • Contact the payment provider;
  • Obtain professional compliance or legal advice;
  • Report the matter to an appropriate authority where required or permitted; or
  • Take any other action reasonably necessary to protect the business and its users.

COMEX Alert may take such action without advance notice where providing notice could compromise an investigation, violate the law or increase financial-crime risk.

15. Suspicious Transaction Reporting

Where COMEX Alert is legally required to report suspicious activity, the report will be made to the appropriate financial intelligence unit, law-enforcement agency, regulator or other competent authority.

COMEX Alert may also cooperate with lawful requests from:

  • Courts;
  • Law-enforcement agencies;
  • Financial intelligence units;
  • Tax authorities;
  • Sanctions authorities;
  • Regulators;
  • Banks;
  • Card networks; or
  • Payment service providers.

Information will be disclosed only where there is a lawful basis or where disclosure is reasonably necessary to prevent fraud, financial crime or harm.

16. No Tipping Off

Where a report or investigation is confidential, COMEX Alert may be legally prohibited from informing the affected user that:

  • A report has been submitted;
  • An authority has requested information;
  • An investigation is taking place; or
  • A transaction has been delayed for compliance reasons.

Nothing in this Policy requires COMEX Alert to disclose confidential monitoring methods, risk indicators or reporting decisions.

17. Refunds and Return of Funds

Approved refunds will normally be returned only to the original payment method used for the purchase.

COMEX Alert will not normally:

  • Refund a payment to an unrelated person;
  • Transfer a refund to a different bank account;
  • Send a refund to a different card;
  • Convert a card payment into cryptocurrency;
  • Return funds to a wallet different from the originating wallet; or
  • Use refunds as a method of transferring money between parties.

Additional verification may be required before a refund is processed.

A payment may be retained, frozen, reversed or referred to the payment provider where required by law, court order, sanctions restrictions or payment-network rules.

18. Third-Party Payment Providers

COMEX Alert may use independent payment gateways, banks, merchant processors or fraud-prevention providers.

These providers may:

  • Collect and verify payment information;
  • Conduct fraud and sanctions screening;
  • Apply their own transaction limits;
  • Request identity documents;
  • Delay or reject transactions;
  • Reverse payments;
  • Retain records; and
  • Report suspicious activity under their own legal obligations.

Use of a third-party payment service is also subject to that provider’s terms, policies and verification requirements.

COMEX Alert is not responsible for a payment provider’s independent compliance decisions.

19. Data Protection and Confidentiality

Personal information collected for AML, sanctions or fraud-prevention purposes will be handled in accordance with our Privacy Policy and applicable data-protection laws.

Information may be used for:

  • Identity verification;
  • Risk assessment;
  • Fraud prevention;
  • Sanctions screening;
  • Payment processing;
  • Compliance monitoring;
  • Dispute resolution;
  • Record keeping; and
  • Responding to lawful authority requests.

COMEX Alert will take reasonable steps to restrict access to compliance information to authorised persons and service providers.

20. Record Keeping

COMEX Alert may retain records relating to:

  • Customer identification;
  • Verification documents;
  • Payment transactions;
  • Refunds and chargebacks;
  • Risk assessments;
  • Sanctions and PEP screening;
  • Customer communications;
  • Suspicious activity reviews;
  • Account restrictions;
  • Reports to authorities; and
  • Decisions to accept or reject transactions.

Records may be retained for at least five years after the relevant transaction or end of the customer relationship, or for another period required or permitted by applicable law.

Information may be retained for longer where necessary for legal proceedings, regulatory enquiries, fraud prevention or the establishment, exercise or defence of legal claims.

21. Employee and Contractor Responsibilities

Relevant employees and contractors must:

  • Understand this Policy;
  • Remain alert to suspicious activity;
  • Protect confidential customer information;
  • Escalate concerns to the responsible person;
  • Avoid informing users about confidential reports;
  • Complete appropriate compliance training; and
  • Follow applicable internal procedures.

A person who identifies suspicious activity must not approve or ignore the activity without appropriate review.

22. AML Compliance Responsibility

Responsibility for overseeing this Policy is assigned to:

AML responsible person: [Insert name or job title]
Business name: [Insert registered company name]
Jurisdiction: [Insert country]
Compliance email: [Insert compliance email address]

The responsible person’s duties may include:

  • Reviewing financial-crime risks;
  • Maintaining this Policy;
  • Reviewing escalated transactions;
  • Coordinating staff training;
  • Maintaining compliance records;
  • Communicating with payment providers;
  • Obtaining legal advice where required; and
  • Reporting suspicious activity where legally required.

23. User Responsibilities

By using COMEX Alert, you confirm that:

  • You are using your genuine identity;
  • Information supplied by you is accurate;
  • Your payment method is lawfully owned or authorised;
  • Payments are made from legitimate funds;
  • You are not acting for a prohibited or sanctioned person;
  • You will provide reasonable verification information when requested;
  • You will not use COMEX Alert for unlawful purposes; and
  • You will comply with applicable laws in your jurisdiction.

Providing false or misleading information may result in immediate suspension or termination.

24. Refusal, Suspension and Termination

COMEX Alert reserves the right to refuse, suspend or terminate a service where:

  • Required verification is not completed;
  • Information appears false or misleading;
  • Suspicious activity is identified;
  • A sanctions concern exists;
  • Fraud or chargeback abuse is suspected;
  • A payment provider requests restriction;
  • Continued service may expose COMEX Alert to legal or reputational risk;
  • A user violates this Policy or the Terms & Conditions; or
  • COMEX Alert is required to do so by law.

COMEX Alert is not obligated to provide detailed reasons where disclosure is restricted by law or could compromise its compliance controls.

25. Geographic Restrictions

COMEX Alert may restrict access from countries or territories where:

  • Its services are prohibited;
  • Sanctions restrictions apply;
  • Payment processing is unavailable;
  • Financial-crime risk is considered unmanageable; or
  • Providing the service would create an unacceptable legal or regulatory risk.

The list of restricted locations may change without prior notice.

Users must not use VPNs, proxies, false addresses or other methods to circumvent a lawful geographic restriction.

26. Policy Review

This Policy will be reviewed periodically and may be updated to reflect changes in:

  • Applicable laws;
  • Sanctions requirements;
  • Payment-provider rules;
  • Business activities;
  • Products and services;
  • Identified financial-crime risks; or
  • Internal procedures.

The revised version will be published on this page with an updated “Last Updated” date.

Continued use of COMEX Alert after an update constitutes acknowledgement of the revised Policy.