Table of Contents

Compliance & Governance

SAHEL Minerals Export Company Limited operates through a documented legal, regulatory, tax and compliance framework in The Gambia.

The company is duly registered to conduct business in The Gambia and holds a Special Licence authorising it to possess and deal in gold and other precious metals. SAHEL Minerals also maintains a Taxpayer Identification Number issued by the Gambia Revenue Authority.

SAHEL Minerals recognises that the gold and precious metals sector requires enhanced discipline in licensing, seller verification, counterparty due diligence, responsible sourcing, anti-money laundering, sanctions screening, transaction monitoring, export documentation and record-keeping.

The company’s compliance framework is built around the following pillars:

  • corporate registration and legal existence;
  • mineral dealing authorisation under its Special Licence;
  • tax registration, reporting and record-keeping discipline;
  • AML/CFT, KYC and sanctions controls;
  • source-of-funds and source-of-metals review;
  • responsible sourcing and supply-chain due diligence;
  • controlled export documentation and logistics procedures.

Corporate Registration

SAHEL Minerals Export Company Limited is registered in The Gambia under the name SAHEL MINERALS EXPORTS COMPANY LIMITED.

The company’s Certificate of Business Registration states that it is registered to carry on business in The Gambia, with business activities described as: “Engage in sourcing, processing, marketing and export of precious minerals, gold and diamond.”

The certificate records the company’s place of business as Sky Blue Plaza, Brusubi, West Coast, The Gambia, and was issued under the seal of the Registrar of Companies on 20 June 2025.

Special Licence to Deal in Gold and Precious Metals

SAHEL Minerals Export Company Limited holds a Special Licence issued by the Geological Department of The Gambia under the Mines and Quarries Act 2005.

The Special Licence is granted to SAHEL Minerals Export Company Limited and authorises the company to “possess and deal in gold and other precious metals.”

The licence is valid for one year, with effect from 7 November 2025 to 7 November 2026, and bears reference number REF: SL/14/2025 SM(1).

The related licence terms and conditions further confirm that the Special Licence is issued to SAHEL Minerals Export Company Limited to deal in gold and precious metals, and that the licence holder must comply with the Mines and Quarries Act, applicable regulations and the conditions attached to the licence.

Licence Conditions and Operating Obligations

The Special Licence terms require SAHEL Minerals to operate within a controlled and documented framework. Among other obligations, the licence terms provide that:

  • a Special Licence is required to deal in restricted minerals;
  • no person may purchase restricted minerals unless properly licensed;
  • a dealer must operate from a permanent place of business;
  • the licence holder must satisfy itself that the seller is authorised to possess and dispose of the minerals;
  • the licence holder must maintain complete, accurate and current books, records, reports and accounts;
  • records must include details of purchases, the nature and weight of minerals purchased, the date of purchase, and the name, title and address of the vendor or agent;
  • books and records must be produced for inspection by Government officers when required.

These obligations form the basis of SAHEL Minerals’ internal compliance, record-keeping, supplier verification and transaction documentation procedures.

Tax Registration

SAHEL Minerals is registered with the Gambia Revenue Authority and has been issued a Taxpayer Identification Number certificate.

The TIN certificate identifies the taxpayer as SAHEL MINERALS EXPORTS COMPANY LIMITED, records the TIN as 2500287387, and states that the certificate was issued by the Gambia Revenue Authority on 29 March 2025.

The company recognises that tax registration is an important component of lawful trading, fiscal transparency and counterparties’ due diligence review. The TIN certificate should not be presented as a tax clearance certificate.

AML/CFT, KYC and Responsible Sourcing Controls

SAHEL Minerals recognises that gold and precious metals trading requires enhanced compliance discipline, including anti-money laundering, counter-terrorist financing, sanctions screening, source-of-funds review, source-of-metals verification and responsible supply-chain controls.

As part of its counterparty onboarding and trading relationships, SAHEL Minerals has completed detailed compliance documentation covering corporate KYC, beneficial ownership, authorised signatories, AML/CFT risk assessment, responsible sourcing, sanctions confirmations, source-of-funds and source-of-metals declarations.

SAHEL Minerals’ onboarding documentation identifies the company, its directors, beneficial owners and authorised traders, and confirms the company’s business profile as a precious metals trader/dealer and exporter. The corporate KYC materials also record that SAHEL Minerals works with gold and precious metals, including alluvial gold, and identifies its counterparties and suppliers as mines, banks and reputable precious metals traders.

SAHEL Minerals has also completed AML/CFT risk assessment documentation addressing customer due diligence, sanctions screening, transaction monitoring, suspicious transaction reporting, record-keeping, supply-

chain risk, geographic risk, customer risk, product and transaction risk, and enhanced due diligence for higher-risk customers and transactions.

Source of Funds and Source of Metals Declaration

SAHEL Minerals supports the use of formal source-of-funds and source-of-metals declarations in precious metals transactions.

The company has provided compliance undertakings confirming that funds and metals used in connection with precious metals trading must be acquired from legitimate sources, supported by evidence where required, and must not originate from sanctioned countries, sanctioned entities or sanctioned persons.

SAHEL Minerals’ compliance approach also recognises international responsible sourcing expectations, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, UAE responsible sourcing regulations, DMCC due diligence rules, LBMA Responsible Gold Guidance and RMI standards.

Sanctions, Conflict Financing and Human Rights Safeguards

SAHEL Minerals does not knowingly deal in metals, funds or counterparties connected to:

  • sanctioned countries, entities or persons;
  • money laundering or terrorist financing;
  • conflict financing;
  • criminal funding;
  • illicit trade in precious metals;
  • worst forms of child labour;
  • human rights abuses;
  • fraudulent or undocumented mineral ownership;
  • smuggling or unlawful export activity.

The company’s compliance undertaking confirms that sources of precious metals should be free from conflict financing, criminal funding, worst forms of child labour and human rights abuses, and that supply-chain information may be requested for due diligence purposes.

Customer Due Diligence and Beneficial Ownership

SAHEL Minerals applies a risk-based KYC approach to counterparties and suppliers.

This may include collection and review of:

  • corporate registration documents;
  • trade licences or mineral dealing authorisations;
  • beneficial ownership information;
  • director and authorised signatory identification;
  • source-of-funds and source-of-wealth information;
  • source-of-metals declarations;
  • sanctions and watchlist screening;
  • supplier profile and country-of-origin information;
  • transaction purpose and expected activity;
  • supporting invoices, shipping records and export documents.

SAHEL Minerals’ completed KYC documentation identifies its beneficial owners, directors and authorised traders and confirms that the company is structured as a private limited company registered in The Gambia. Personal identification, residential address and bank account information should not be published on the website.

Seller Authority and Source-of-Minerals Review

The Special Licence terms require the licence holder to satisfy itself that the seller is authorised to possess and dispose of the relevant minerals. SAHEL Minerals therefore applies seller verification and source-of-minerals checks before purchasing, exporting or facilitating transactions in gold or precious metals.

SAHEL Minerals does not knowingly deal in minerals that are stolen, illegally mined, fraudulently represented, linked to sanctioned persons or jurisdictions, connected to conflict financing, or otherwise inconsistent with lawful and responsible trade.

Transaction Monitoring and Red Flags

SAHEL Minerals monitors transactions for unusual or suspicious features and may request additional documentation where required.

Potential red flags include:

  • incomplete or inconsistent seller documentation;
  • unclear source of minerals;
  • unexplained ownership history;
  • unusual payment routes;
  • request for cash or third-party payments;
  • involvement of undisclosed intermediaries;
  • sanctions, adverse media or PEP concerns;
  • transactions involving high-risk jurisdictions;
  • reluctance to provide KYC or source-of-metals documents;
  • pressure to bypass customs, export or compliance procedures.

The company’s AML/CFT risk assessment documentation addresses transaction monitoring, unusual activity, suspicious transaction reporting, red-flag indicators and record-keeping for client and transaction records.

Books, Records and Government Inspection

SAHEL Minerals maintains transaction records to support auditability, regulatory review and commercial transparency.

These records may include:

  • date of purchase;
  • seller or vendor details;
  • mineral description;
  • weight and form of the mineral;
  • purchase price and payment records;
  • KYC and due diligence documents;
  • export and customs documents;
  • shipment and chain-of-custody records;
  • refinery or destination-side settlement records.

The Special Licence terms require books, records and accounts to be maintained in sufficiently comprehensive detail to present a true, clear and accurate record of the company’s activities, transactions, costs, expenditures and receipts. The company is also required to produce such books for inspection by Government officers when required.

SAHEL Minerals’ AML/CFT documentation also confirms record-keeping controls, including maintaining client and transaction records and retaining customer due diligence and business correspondence for at least five years after the end of a customer relationship.

Responsible Supply Chain

SAHEL Minerals seeks to support responsible precious metals supply chains.

The company’s compliance documentation confirms that it has addressed responsible supply-chain expectations for gold from conflict-affected and high-risk areas and that it intends to comply with OECD-style responsible sourcing principles.

SAHEL Minerals may request supply-chain information, seller declarations, origin documentation, transport records and other supporting materials before accepting a transaction or shipment.

Export Documentation and Logistics Controls

SAHEL Minerals coordinates export activity through formal documentation and controlled logistics procedures.

This may include:

  • licence and export authority review;
  • seller and transaction documentation checks;
  • customs and export paperwork;
  • packing lists and shipment records;
  • chain-of-custody procedures;
  • secure transport coordination;
  • insurance and logistics documentation where applicable;
  • destination-side import, refinery or trading interface.

The company’s objective is to reduce operational risk by ensuring that each stage of the transaction is documented, traceable and professionally managed.

Governance and Internal Oversight

SAHEL Minerals applies internal governance procedures designed to ensure that transactions are reviewed before execution and that material risks are escalated appropriately.

The company’s governance approach includes:

  • management oversight of transaction approvals;
  • documentation review before purchase or shipment;
  • counterparty and seller due diligence;
  • internal escalation of red flags;
  • transaction file maintenance;
  • use of professional advisers and service providers where required;
  • periodic review of procedures to reflect business, regulatory and market developments.

Regulatory Cooperation

SAHEL Minerals recognises that its licensed activities are subject to regulatory supervision.

The company maintains books and records in The Gambia and cooperates with lawful requests from competent government officers, including requests to inspect relevant books, records and transaction documentation.

SAHEL Minerals seeks to maintain an open and professional relationship with regulators and public authorities responsible for mineral resources, licensing, customs, taxation and export controls.

Professional Counterparties Only

SAHEL Minerals is positioned for serious, professional counterparties.

The company does not encourage speculative, undocumented or informal transactions. Counterparties are expected to provide accurate information, cooperate with due diligence requests, observe applicable law and conduct themselves in a professional manner.

SAHEL Minerals may decline to engage with counterparties who are unwilling or unable to satisfy its compliance, documentation or governance requirements.

Regulatory References

SAHEL Minerals Export Company Limited maintains the following core corporate, regulatory and compliance documents:

  • Certificate of Business Registration – issued in The Gambia on 20 June 2025.
  • Taxpayer Identification Number Certificate – TIN 2500287387, issued by the Gambia Revenue Authority on 29 March 2025.
  • Special Licence – REF: SL/14/2025 SM(1), authorising the company to possess and deal in gold and other precious metals, valid from 7 November 2025 to 7 November 2026.
  • Terms and Conditions for Special Licence – governing the company’s licence obligations, seller verification, record-keeping, inspection duties and compliance with the Mines and Quarries Act.
  • Corporate KYC, AML/CFT risk assessment and source-of-funds/source-of-metals compliance undertakings – maintained internally and available to approved counterparties, financial institutions, logistics providers, refineries and competent authorities subject to appropriate confidentiality and data protection requirements.

Availability of Compliance Documentation

Copies of SAHEL Minerals’ corporate, licensing, tax and compliance documentation may be made available to approved counterparties, financial institutions, logistics providers, refineries and competent authorities subject to appropriate confidentiality, data protection and due diligence requirements.

Important Notice

The information on this page is provided for general corporate and compliance transparency purposes only. It does not constitute legal, tax, regulatory, financial or investment advice. SAHEL Minerals’ activities remain subject to applicable laws, regulations, licence conditions, contractual terms and regulatory requirements in each relevant jurisdiction.

All transactions remain subject to due diligence, documentation review, internal approval, regulatory compliance and final agreement between the parties.

Compliance Contact

SAHEL Minerals Compliance

Email: exports@sahelminerals.com

Phone: +220 200 3638

Banjul Office

Brufut, Taf Madiba Mall

Banjul, The Gambia

Dubai Office

c/o GAMMA METALS DMCC

DMCC Business Centre

Level No. 1, Jewellery & Gemplex 3

Dubai, United Arab Emirates