Prevention of Money Laundering and Financing of Terrorism Manual


This manual is to establish the rules and procedures necessary for the fulfillment of what is established in the current legislation concerning the prevention and detection of money laundering and to prevent our society being used in financing terrorism or other criminal activities.

Being LIBERTYORO S.L. a retail trade sales, will proceed to the formal identification of the customer in accordance with Articles 4 and 6 of the Regulation of the Law 10/2010 of April 28th. Concerning the prevention of money laundering and the financing of terrorism. LIBERTYORO S.L. will retain the documentation of transactions in accordance with Articles 28 and 29 of the Regulation of the Law 10/2010.

LIBERTYORO S.L. record the identification details of customers and transactions in a logbook, in physical or electronic form, which is available to the Commission for the prevention of money laundering and monetary offences, bodies of support or any other legally authorized public authority. To this end, shall take effect the logbook that the Article 91 of the RD197 / 1988 of February 22nd., Regulation of the Law 17/1985, of July 1st., refers to manufactured objects approved which concerns precious metals. LIBERTYORO S.L. records all operations and sends weekly the logbook to the specialist crime unit and violent provincial brigade of the judicial police of Valencia, robbery group II.


The retail activity LIBERTYORO S.L. entails two inherent risks: retail buying of jewelry of illegal provenance and money laundering operations selling gold and silver investments.

Control protocol on the purchases of jewelry: LIBERTYORO S.L. fullfils the protocols required by the robbery II group, specialist crime unit and violent provincial brigade of the judicial police of Valencia, where it is duly registered.

Control protocol on the sales of investment gold and silver: LIBERTYORO S.L. complies with the law of prevention and fights against tax fraud, in particular the limitation of cash payments over 2.500€. All sales transactions exceeding 2.500€ are made through banks.

The software used by LIBERTYORO S.L. keeps a record of each transaction and includes customizable analysis tools to detect and prevent operations of BC / FT.


The first filter system of Liberty Gold prevention lies in establishing relationships with customers. Customer means any natural or legal person in any capacity (holder, authorized representative, etc.) involved in the hiring of any product and / or other service marketed by LIBERTYORO S.L.

In order to reach the determination of the actual owner of the operation carried out and the knowledge of the origin of the funds used by customers, it is to be labelled by supporting documents as many natural or legal persons seeking to establish business relations or intervene in any operations .


  • Individuals:
    - NIE/DNI
    - Passport or valid identification in the country of origin including a photograph of the holder.
    - Residence permit
  • Legal entities:
    - Writing constitution that conclusively stating their name, legal form, address and corporate purpose.
    - Tax Identification Number (NIF).
    - Empowerment documents of persons acting on their behalf and documents identifying them.
    - Shareholding structure or control of the entity.

The software used for the activity is fully adapted to comply with the rules of identification on BC / FT. The software keeps track of customers and operations.


LIBERTYORO S.L. has a data analysis software that can recognize signs and patterns BC.

  • All operations recorded include: Customer identification, date and amount of the transaction.
  • Record cash transactions: The software prevents cash collection of amounts exceeding 2.500€, according to Royal Decree 304/2014, of May 5th. on the Regulation of Law 10/2010 is approved, April 28th. on the prevention of money laundering and terrorist financing.
  • Transactions with credit / debit cards. LIBERTYORO S.L. act with due diligence in detecting fraud with electronic payment means any payment attempt communicating by electronic means other than the name listed as a customer identified in the operation.


LIBERTYORO S.L. periodically, at least once a year, has an audit to check that the measures taken to fight against BC / FT are effective. If you detect any possible improvement LIBERTYORO S.L. update the protocols, if necessary.