1. Why we have an AML programme
Precious-metals dealers in Israel operate under anti-money-laundering and counter-terrorism-financing obligations that flow from Israel's Prohibition on Money Laundering Law and the regulations issued under it. Our programme is designed to verify customer identity, understand the source of funds used to purchase silver, screen against sanctions lists, and report suspicious activity to the competent authorities when required.
2. Customer due diligence (CDD)
We apply two CDD levels depending on the order value and the customer profile:
Standard
Orders under ₪5,000.
- Full legal name, contact email and phone.
- Israeli delivery address.
- Email verification (one-time code).
Enhanced
Orders at or above ₪5,000.
- Government-issued ID — Teudat Zehut for Israeli residents, passport for non-residents.
- Proof of address (utility bill, bank statement, or municipal letter, dated within 90 days).
- Source-of-funds declaration with supporting documentation (e.g. salary, sale of property, gift, inheritance).
- Sanctions and politically-exposed-person screening.
3. Cash and payment policy
We do not accept cash for bullion orders. All payment is by Israeli bank wire only, in shekels, from an account in the customer's name. Payments from third-party accounts will be returned. This policy directly supports source-of-funds traceability and reduces money- laundering risk.
4. Sanctions and PEP screening
For enhanced-CDD orders we screen names against applicable international sanctions lists and politically-exposed-person databases as part of our verification process. A match — or a near-match we cannot rule out — will trigger additional review and, where required, refusal of the transaction.
5. Suspicious activity reporting
Where we have reasonable grounds to suspect that a transaction is connected to money laundering or terrorism financing, we are required by Israeli law to report it to the Israel Money Laundering and Terror Financing Prohibition Authority (IMPA). We do not disclose to the customer that a report has been made, as required by anti-tipping-off rules.
6. Record-keeping
We retain customer identification records, transaction records, and supporting documentation for at least seven years from the end of the customer relationship or the date of the transaction, consistent with Israeli AML and tax record-keeping requirements. Records are stored securely with access limited to authorised personnel.
7. Staff training
All staff involved in customer onboarding, payment reconciliation, or order fulfilment receive training on our AML programme, red-flag indicators, and reporting obligations. Training is refreshed periodically and whenever procedures materially change.
8. Customer cooperation
We may need to contact you to clarify identity documents, verify source of funds, or ask follow-up questions. Failure to respond, or provision of incomplete or inconsistent information, may result in delay or refusal of the transaction. Cooperation keeps the process fast and avoids unnecessary friction.
9. Right to refuse
We reserve the right to refuse any transaction that we cannot reconcile with our compliance obligations, that fails sanctions screening, or that we have reasonable grounds to believe is connected to unlawful activity. Where we refuse, we will return any funds received, less any costs incurred, by the same payment channel.
10. Compliance contact
For compliance-related enquiries, contact our designated compliance officer via info@lavisilver.com.