Anti-Money Laundering

AML Policy                                                                                                                              

Borger Capital Group LLC has voluntarily established a risk-based AML Program.  It is the Policy of the Company to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by voluntarily complying with applicable requirements under the Bank Secrecy Act, as amended by the USA PATRIOT Act and all related implementing regulations.

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The AML Program will be reasonably designed to prevent the Company from being used to facilitate money laundering and the financing of terrorist activity through the purchase of precious metals.  The AML Policy will be reviewed and updated by the designated AML Compliance Officer on a regular basis, at a minimum annually, to ensure appropriate procedures and internal controls are in place to account for both changes in regulations and changes in the Company’s business.  To accomplish this, the Company will conduct an annual AML risk assessment.  The results of the risk assessment will drive improvements in the Company’s AML risk management by identifying money laundering risks, assessing how these risks are controlled and mitigated, determining the remaining residual risk, and identifying possible enhancements to existing controls, including policies, procedures, and processes.