Privacy Policy

Anti-Money Laundering (AML) Policy

GLX Consultoria

GLX Consultoria is firmly committed to conducting business with the highest levels of integrity and in full compliance with applicable anti-money laundering regulations, including those enforced across the European Union. This policy outlines our approach to identifying, managing, and mitigating the risks of money laundering and financial crime associated with the global trade in gemstones.

We actively support and protect the integrity of the legitimate gemstone trade and are dedicated to maintaining a secure, transparent, and compliant operating environment.

Due to the nature of the gemstone and luxury goods industry, the following risks are most commonly associated with money laundering:

• False declarations on import/export documentation, including under- or over-valuing goods, misreporting quantities, or shipping items not reflected on official invoices
   
• Receipt or transfer of funds from illegitimate sources, especially from jurisdictions with weak financial regulation or limited transparency
   

It is the policy of GLX Consultoria to proactively prevent any use of our business in connection with money laundering activities. Our AML framework is designed to meet both legal requirements and industry best practices, and it is reviewed regularly to ensure continued relevance and effectiveness.

Our procedures apply across all business operations, including sourcing, sales, and logistics.

We maintain strict pricing integrity to ensure that products are not manipulated to support transfer pricing schemes, or illicit fund movement. Prices reflect the fair market value of gemstones, as verified by international certification and prevailing trading conditions.

All diamonds and gemstones sold by GLX Consultoria are matched against their corresponding certification—such as GIA, GRS, SSEF, Gübelin, or AIG—to ensure authenticity and full traceability. Microscopic inscriptions and certificate details are verified during our internal quality control process to prevent the circulation of non-certified or fraudulently documented stones.

GLX Consultoria has appointed a dedicated AML Compliance Officer, who holds overall responsibility for the firm’s anti-money laundering program. Key responsibilities include:

• Overseeing AML compliance across all departments
   
• Ensuring all funds received are from legitimate, verifiable sources
   
• Verifying that goods are accurately valued and declared
   
• Investigating any signs of suspicious or irregular activity
   

GLX Consultoria enforces strict KYC measures for all clients and suppliers before initiating any business relationships.

A. Onboarding Process
New clients and suppliers must complete a detailed KYC form and provide appropriate identification, proof of address, business registration, and any other relevant documentation.

B. Refusal to Comply
If a party refuses to provide required information, or provides suspicious or misleading details, GLX Consultoria reserves the right to deny or terminate the relationship immediately.

C. Verification of Information
All KYC information is verified prior to account activation or order fulfillment. Transactions may be delayed or declined until verification is complete, depending on the risk level.

We continuously monitor transactional behaviour across all accounts. Our systems flag activity that may suggest abnormal or high-risk patterns, including unusual payment structures, unexplained high-volume orders, or inconsistencies between invoice values and market rates.

The AML Compliance Officer regularly reviews these alerts and determines if further scrutiny or reporting is required.

When red flags are triggered—either through automated alerts or employee observation—they are immediately escalated to the AML Compliance Officer for investigation.

Depending on the nature of the concern, GLX Consultoria may:

• Request additional documentation from the party involved
   
• Place a temporary hold on the transaction
   
• Decline the order entirely
   
• File a report with the appropriate legal or regulatory authority
   

All investigations and decisions are documented and stored securely in compliance with data protection regulations.

GLX Consultoria takes a proactive and transparent stance on anti-money laundering compliance. We are committed to ethical trading practices, secure financial transactions, and active participation in global efforts to eliminate financial crime from the gemstone industry.

This AML Policy is reviewed and updated regularly to reflect changes in legislation, risk exposure, and operational scope.