Anti-Money Laundering & Counter-Terrorism Financing (AML/CTF) Policy

Rosendorff (WA) Holdings Pty Ltd trading as Rosendorff Diamond Jewellers — ABN 56 698 951 129. Version 1.0, effective 17 August 2026. Approved by the Managing Director.

Our Commitment

Rosendorff Diamond Jewellers is committed to preventing our business from being used for money laundering or terrorism financing. As a retailer of high-value diamond and precious-metal jewellery, we maintain controls that meet or exceed the requirements of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and AUSTRAC guidance, across our Perth showroom and our online store.

Governance

The Managing Director is our designated Money Laundering Reporting Officer (MLRO) and AML Compliance Officer, responsible for customer due diligence, sanctions screening, escalations, record keeping and staff training. This policy is reviewed at least annually.

Key Controls

• No large cash: we do not accept physical cash of AUD $10,000 or more. Payments are accepted through traceable methods only (card via Shopify Payments, bank transfer, approved instalment providers). We do not accept cryptocurrency or third-party payment instruments.
• Enhanced due diligence: every transaction at or above AUD $10,000 requires government photo ID verification, matching of the payment method to the verified identity, and screening against the DFAT Consolidated List, UN Consolidated List and OFAC SDN List before goods are released. Transactions at or above AUD $50,000 additionally require documented source-of-funds evidence and MLRO sign-off.
• Monitoring: staff are trained to identify red flags — structuring, third-party payers, refusal to identify, unusual shipping requests, refund cycling — and must escalate to the MLRO before completing a sale. Refunds are only ever made to the original payment method.
• Reporting: suspicious activity is declined and reported to relevant authorities as required by law.
• Records: due diligence and transaction records are retained securely for at least 7 years, in accordance with the Privacy Act 1988 (Cth).

See also our Know Your Customer Policy and Sanctions Policy.