Terms & Conditions · AML / KYC / KYB

Owner of the Metal Bank

The provider of the LBMA physical gold sales service that offers THE REAL MONEY's clients services and products related to physical gold is Real Money Europe Limited, registration number 813181, Block 4 Harcourt Centre, Harcourt Road, Dublin 2, D02 HW77, Dublin, Ireland. Physical gold Metal Bank.

Every product and activity relating to the sale, purchase, supply, custody and advice on LBMA gold is managed by Real Money Europe, which is governed by Irish law. All references on the REALMONEYEU.COM platform relating to LBMA physical gold are products and services provided by Real Money Europe Ltd. (hereinafter also referred to as the METAL BANK).

• The METAL BANK oversees the deposits that clients open for the custody of the physical gold they buy.
• Deposit plans may offer different options and vary in volume, activation fee, custody fee, insurance fee, management fee, etc. The METAL BANK may, at its sole discretion, modify, remove, suspend or create deposit plans and the associated general conditions.
• The METAL BANK manages the custody of the gold purchased by clients at its discretion, also using external LBMA maximum-security vaults, taking into account logistics and the most favourable prices or services without limiting the maximum possible guarantee and security for the client's protection.

Services and custody plans

The METAL BANK offers the following services:

• Purchase of LBMA physical gold;
• Shipment of the purchased gold to your home;
• Storage of the purchased gold in maximum-security vaults;
• Management of the buying and selling processes of gold in custody;
• Administration of the deposit plan on behalf of the Beneficial Owner;
• Issuance of deposit ownership certificates;
• Issuance of digital blockchain certificates for the valuation of the deposit at a given date;
• Creation of bars in different formats;
• Customised custody services (INOUT, PREMIUM PLUS, STABILITY, FUTURE, RELAX, etc.);
• Purchase price coverage.

Onboarding process and anti-money laundering compliance

3.1 · Why we are subject to AML regulations

The METAL BANK (hereinafter «METAL BANK» or «the Company») is committed to combating money laundering and terrorist financing. This is a fundamental commitment, not merely a regulatory obligation.

We believe that a healthy and transparent precious metals market requires responsible operators who apply high standards of due diligence with their clients. This Policy transparently describes our approach to preventing financial crime, the procedures we use to verify our clients' identity and the criteria we use to assess the risk associated with each business relationship.

3.2 · Regulatory references

3.3 · Glossary

3.4 · Why we verify your identity

Identity verification is not just a legal requirement: it is the main tool the METAL BANK uses to protect its clients and ensure the integrity of the physical gold market. The main risk for the METAL BANK is being unintentionally involved in unlawful activities. These controls protect both the METAL BANK and, more importantly, our clients, ensuring a safe and reliable environment.

3.5 · Our approach: Risk-Based and Human-First

The METAL BANK adopts a risk-based approach (RBA), in accordance with the FATF Recommendations for precious metals operators (updated in 2024). This means that:

• We do not treat all clients equally: those with higher-risk characteristics undergo more thorough controls;
• Persons with a documented low-risk profile can access services through more streamlined procedures;
• Compliance resources are concentrated where the risk is greatest, without unnecessarily burdening the experience of low-risk clients.

Our approach combines on-site identification —carried out by our staff— with thorough documentation verification. Clients are classified into three risk categories —LOW, MEDIUM and HIGH— based on factors such as country of residence, type of transaction and whether they are a Politically Exposed Person (PEP) or a sanctioned entity.

3.6 · How we verify your identity

3.6.1 · The KYC process for individuals. The identity verification (KYC) process for individual clients always involves direct, in-person contact between the client and the METAL BANK. There is no option to complete the KYC process automatically or without human interaction.

3.6.2 · Purpose and nature of the business relationship. The METAL BANK collects information directly from the client to understand the purpose of the business relationship, including: types of transactions envisaged (spot purchase, instalment plans, partial sales); source of the funds used to buy gold; and general experience and knowledge of precious metals investments.

3.6.3 · The KYB process for legal entities. For clients that are legal entities (companies, corporations, foundations, trusts), the KYB process requires additional documentation:

• a) Copy of the updated articles of association and incorporation;
• b) LEI code, if available;
• c) Commercial Register certificate or equivalent (no older than 3 months);
• d) Latest approved financial statements;
• e) Identity documents of directors and members/shareholders with a holding over 25%;
• f) Complete ownership structure and identification of the ultimate beneficial owners (UBO);
• g) Copy of the VAT certificate if present;
• h) Sector of activity and motivation for investing in physical gold.

3.6.3.1 · Identification of the Ultimate Beneficial Owner (UBO). For legal entities: the natural person who directly or indirectly owns or controls more than 25% of the capital or voting rights, or who exercises management control. In their absence, the beneficial owner is the legal representative. For trusts and similar entities: the settlor, the trustee, the protector and the beneficiaries. For each UBO, the company obtains a signed declaration, verifies identity and carries out a check against PEP and international sanctions lists.

3.7 · How we assess each client's risk

3.8 · Client verification

3.9 · Politically Exposed Persons (PEP)

A PEP is a natural person who holds or has held a prominent public office. Examples include: heads of State and government, ministers and deputy ministers; members of Parliament and legislative assemblies; members of the governing bodies of political parties; judges of supreme and constitutional courts; ambassadors, chargés d'affaires and high-ranking military officers; members of the administrative bodies of public companies; and close family members and related persons.

The METAL BANK, while recognising the possibility of establishing relationships with PEPs in accordance with current legislation, adopts a prudential policy that provides, in most cases, for the refusal or termination of the relationship, unless the Compliance Officer determines otherwise.

3.10 · Geographical restrictions

The METAL BANK does not accept clients who are residents, domiciled or citizens of countries subject to international restrictive measures by the United States, the European Union or the UN, nor clients who appear on OFAC sanctions lists.

Excluded countries (examples): by way of example, and without being limited to them: Cuba, Iran, North Korea, Syria, Russia (sanctioned entities), and any other country subject to equivalent sanctions regimes. For clients resident in FATF grey-list or high-risk countries, enhanced due diligence (EDD) measures apply, subject to the assessment of the Compliance Officer. The lists are consulted and updated according to official publications by the FATF, the EU, the UN, OFAC and the FIU.

3.11 · Periodic update of the client profile

Verification does not end with onboarding. The METAL BANK may request updates in the event of: expiry of documents; significant change in the operational profile; changes in the ownership structure; regulatory updates; or reports of anomalies. In these cases, it may temporarily suspend access to certain services until the update is completed, always informing the client in advance.

3.12 · Suspicious transactions and reporting obligations

The company is required by law to report to the FIU any transaction in which it suspects, or has reasonable grounds to suspect, that money laundering or terrorist financing is taking place.

3.13 · Your rights

Compliance/Privacy contact: privacy@realmoneyeu.com · Website: www.realmoneyeu.com — Privacy Policy · Registered office: Block 4 Harcourt Centre, Harcourt Road, Dublin 2, D02 HW77, Dublin, Ireland.

Procedures for buying gold

The purchase of gold takes place after positive confirmation of the onboarding process. Once complete, access to the client's reserved area is confirmed to manage the functions available on the Platform: buying, selling and custody. Access is granted through a free membership. LIBERTY is the membership that allows you to start operating with the basic functions of the physical gold purchase and custody plans.

Public purchase price

The «PUBLIC PRICE» is the price set by the metal bank by applying an additional value to the London reference price (FIXING), which may vary according to market trends and the bank's own strategies. The price shown at the London fixing does not correspond to the «PUBLIC PRICE» shown by the METAL BANK at the time of purchase.

Indicative sale price

The public sale price, not yet set as definitive, is called the «INDICATIVE SALE PRICE». It is shown during the purchase process and is considered indicative until the effective completion of the process by the METAL BANK.

Definition of the purchase price

The purchase price is set once the process is complete. The final price is shown in the reserved area, indicating the number of grams purchased. It may vary from the indicative sale price, as the number of grams purchased may vary according to market trends.

Minimum purchase weight

Unless otherwise agreed, the METAL BANK buys LBMA physical gold pieces of 2 g each. Clients may request that the metal be cast into bars of different weights.

Procedures for buying and selling gold

The gold sale process can be carried out in two ways: sale of gold held in custody on behalf of the client at the METAL BANK, or sale of gold purchased at the METAL BANK but in the client's possession (shipped to their home).

1 · Sale of gold held in custody

The client accesses the sales function from their reserved area and determines how many grams to sell (in 2 g increments). The system provides an «INDICATIVE SALE PRICE», which takes as reference the last London fixing price per gram of LBMA gold. It is indicative, as during the process the price may vary up or down. To proceed, the client confirms by entering the OTP code sent to their mobile.

2 · Execution times for the sale of gold in custody

Once the order is confirmed, we process it immediately. However, the process is not always completed instantly: it may take between 7 and 10 business days if a large-volume gold sale is requested. All ALPHA MEMBERS can access priority processing that reduces the sale process to 72 hours (see the ALPHA section).

3 · Settlement process for the money generated by the sale

Once the sale is complete, the system shows the final price according to the London fixing. The amount is transferred directly to the bank account provided by the client as the main account. The METAL BANK does not charge fees for the sale transaction, but may apply bank charges for the transfer (see the «Costs & Fees» section). The METAL BANK is not responsible for the fees that the receiving bank may apply.

4 · Differences between the purchase price and the sale price of stored gold

It may happen that the sale price is lower than the purchase price. The purchase price is based on the «public sale price» (London fixing plus the charges applied: custody, insurance, storage, etc.). Therefore, selling within a short period of time may generate this discrepancy.

5 · DÚO service

DÚO allows you to avoid selling your gold deposits to obtain liquidity. If activated, it allows you to lock the deposited gold for an advance settlement to your bank account. See the DÚO terms and conditions for more information.

6 · Sale of gold held by the client

The METAL BANK does not usually buy gold outside its own warehouses or from LBMA-certified suppliers. Its policy is not to buy gold that the client holds, even if the bars were purchased directly. However, at its discretion, if it is agreed to start the purchase process, it may be subject to additional costs resulting in a buyback price lower than the London fixing.

Custody plans

Clients who purchase gold can benefit from the custody plans. The custody service is paid and subject to different fees depending on the plan. It allows you to buy LBMA physical gold and have it allocated at the same METAL BANK where you bought it, which will store it and allocate it each time you buy gold above 2 g.

Unlike bank deposits, the custody of LBMA physical gold is not subject to losses and is completely independent of the financial management of the METAL BANK, which, in the event of bankruptcy, is not subject to the €100,000 coverage financial limits imposed by banks. When storing physical gold, the coverage corresponds to the actual value held at the entity.

Storage plans with lock-up

LOCK-UP custody plans provide that the client decides not to sell the stored metal for a contracted period, which may be 12, 24, 36 or 48 months. For this fixed-term deposit period, the METAL BANK applies a series of discounts to the activation cost, the storage cost, the manufacturing cost or the certificate issuance cost. Plans vary according to the lock-up period and maintain the same custody conditions for the allocated gold.

Storage plans with scheduled periodic sale

One of the custody plans allows the automated monthly partial sale of your gold reserves. The gold intended for the monthly sale corresponds to a portion of the stored gold that remains locked for a set period (lock-up) and cannot be sold during that time.

Quotation and public sale price

The METAL BANK quotes the retail price according to the London fixing, to which it adds the costs of the services selected. Therefore, the price it shows is the «PURCHASE PRICE», which is equivalent to the «PUBLIC SALE PRICE». In addition, there is the SALE price, which corresponds to the London Fixing.

Fixing

The gold price fixing is the official mechanism, managed by the LBMA (London Bullion Market Association), to set the reference price of gold twice a day (at 10:30 and 15:00 GMT) in London. This value serves as a global reference for trading physical gold and derivatives. The METAL BANK applies a margin (the difference between the London fixing price and the public sale price) to determine the public sale price.

Cost of services

The METAL BANK charges a fee for its services, which is added to the price of the gold purchased. These fees vary according to the services requested when opening the deposit. We invite you to consult the price list published in the «Costs & Fees» section of its website. Published prices are subject to changes and discounts at the sole discretion of the METAL BANK.

Shipping costs

You may choose not to activate the custody services, but to use the bar casting service and the shipment of the metal to your home. You must provide the desired size of the bars and your residential address. The costs will be shown before you make the transfer for the purchase.

Shipping is managed by specialised security companies that will deliver your gold with full security, using armed escorts, armoured vehicles and specific insurance coverage.

The ALPHA Members section

The ALPHA MEMBER section offers preferential access to the METAL BANK's services. The price is updated annually and shown in the Membership section. The ALPHA MEMBER enjoys priority access and the possibility of receiving additional exclusive services.

The DÚO programme

DÚO is the service that allows the client, owner of the gold deposited at the METAL BANK, not to sell the gold if they need liquidity. It is activated from your reserved area by selecting the amount you wish to activate and locking your gold in deposit. The DÚO system automatically adjusts the maximum value you can access according to the value of your deposit.

Activation involves an activation fee and a maintenance fee in relation to the storage of your gold (see the costs in the «Costs & Fees» section). It requires acceptance of the specific terms and conditions of the DÚO service. During activation, the system shows a pop-up that must be validated with an OTP confirmation code; without it, the service cannot be activated.

Buyback service at an agreed price

It allows you to set the sale price (metal buyback price) at a specific date. It is currently available for the PREMIUM PLUS and RELAX plans. At the end of the lock-up period, the metal buyback price will be paid as stipulated in the deposit contract, without the possibility of amendments except by agreement to the contrary and unilateral acceptance by the METAL BANK. Buyback at an agreed price entails an additional cost to the purchase price (see the table on the «Costs & Fees» page).

Access to the reserved area

Once registration is complete, you will have access to the reserved area where you can manage your account and the selected deposit plans: buy, sell and store your gold, and activate the various services. Each operation requiring the use of a device will be confirmed with an OTP code sent to your phone.

If you receive an OTP code and it is not you who has logged into the reserved area, you must delete the previous access codes and reactivate the new ones to prevent fraudulent access. If necessary, you can request assistance from our technical department at help@realmoneyeu.com.

Faults and reports

Despite our commitment, we may experience interruptions in the METAL BANK's operations due to technical, administrative or logistical problems, among others. To ensure prompt resolution, in addition to accessing each department's email, you can contact the «Complaints» department through the relevant section on our website. Staff will contact you as soon as possible.

Account use restrictions

For various reasons, we may be obliged, at our sole discretion, to restrict the use of your account: security problems in our systems or the need to request additional information about your professional profile or identity. In these cases, you may be asked for the documents needed to complete our due diligence process and allow your account to regain full functionality.

Account cancellation

You can close your account at any time and withdraw all your gold to your home or sell it completely and request a transfer to your bank account.

Likewise, the METAL BANK may close your account without the need for justification, notifying you by email, text message and, if necessary, by post. After notification, your account will be blocked and you will be asked what you wish to do with the gold you hold: sell it and receive the money in your bank account, or collect it at your registered home. If no option is indicated within 30 days of the notification, the METAL BANK will cancel your account and, 90 days after cancellation, will send a bank transfer with the amount generated by the sale of your gold.

Advisory activities

The METAL BANK offers its clients a personalised advisory service through specialised advisors, duly trained to provide adequate information on the services, opportunities and risk levels present in the physical gold sector.