Compliance
Verification, documentation and the limits of what we claim
Aptus Group builds each transaction so that its critical facts are established by parties the buyer chooses: identity through registry records, licence through the issuing authority, purity through an independent laboratory, and export through a customs file whose documents agree with one another. Where a claim cannot be evidenced, we do not make it — and this page lists what those claims currently are.
Buyer qualification
Know your counterparty, in both directions
Qualification runs before commercial terms, not after them. It is mutual by design: everything we ask of a buyer, a buyer is entitled to ask of us.
- Corporate identity
- Registered legal name, registration number and jurisdiction, confirmed against the companies registry rather than against a letterhead.
- Beneficial ownership
- Directors and ultimate beneficial owners, with identity documentation.
- Screening
- Sanctions and politically exposed person screening on the entity and its principals.
- Banking
- Accounts in the registered names of the contracting entities. No third-party accounts, no personal accounts, no cash.
- End use and destination
- The destination market, the intended consignee and, where relevant, the refiner's own acceptance policy for material of this origin.
- Anti-money-laundering context
- Kenya's financial intelligence function sits with the Financial Reporting Centre, and Know Your Source and Know Your Customer expectations aligned to the OECD gold guidance apply across the sector.
Provenance
The OECD framework, and what it means in practice
The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas is the reference framework for this sector. It is a five-step process, not a badge.
Management systems
A company structure that can actually carry a due diligence policy, with named responsibility and record-keeping.
Identify and assess risk
Map the chain from the point of purchase forward, and identify where provenance, documentation and counterparty risk concentrate.
Respond to risk
A written strategy for the risks found, with steps that change what the business does rather than what it says.
Third-party audit
Independent audit of due diligence practice at identified points in the chain — most consequentially at the refiner.
Report
Public reporting on supply chain due diligence, so the framework is checkable from outside.
A large share of Kenyan gold originates in artisanal and small-scale production, which is the part of the chain the framework is most concerned with. That is not a reason to avoid the origin — it is the reason the provenance record has to be assembled deliberately, from the point of purchase forward, rather than reconstructed at export.
Documentation
The export file, and why it has to reconcile
A compliant Kenyan gold export produces a specific set of documents, and they depend on one another: the permit rests on the licence and the assay, the customs entry rests on the permit, the airway bill rests on the entry. That interdependence is what makes a genuine file consistent — and a fabricated one detectable, because names, weights, fineness and dates stop agreeing across the set.
Forged export permits, laboratory reports, freight receipts and airway bills are a standard component of gold fraud in this region. The defence is not a sharper eye for a forgery. It is refusing to rely on any document that cannot be confirmed at source.
Documents a compliant export generates
- Gold export permit — Ministry of Mining, Blue Economy and Maritime Affairs
- Evidence of lawful ownership of the material
- Mineral dealer's trading or processing licence held by the exporter
- Assay certificate establishing fineness
- Tax Compliance Certificate — Kenya Revenue Authority
- Export Declaration Form (EDF)
- Certificate of origin
- Commercial invoice and packing list
- Customs entry and clearance documentation
- Insurance certificate covering the consignment in transit
- Airway bill
Royalty on minerals is a continuing obligation under the Kenyan regime and a rate of five per cent of gross value is widely cited for gold. Fiscal terms are revised from time to time — confirm the position applying on your shipment date.
What we will not claim
An open list of what this site does not yet evidence
Most websites in this sector solve the credibility problem by inventing credentials. We would rather publish the gap. Each item below is being substantiated; until it is, it does not appear as a claim anywhere on this site.
- Company registration number and registered legal entity name
- Mineral Dealer's Trading Licence (MDTL) number and expiry, or the licensed counterparty relied on
- Gold export permit reference issued by the Ministry of Mining, Blue Economy and Maritime Affairs
- KRA PIN and current Tax Compliance Certificate
- Which assay laboratory or refinery issues certificates on our lots
- Whether Aptus Group exports as principal, or facilitates for a licensed exporter
- Insurance underwriter and cover limits for vault storage and in-transit consignments
- Years of operation in gold specifically (2012 refers to the logistics business)
- Any refinery, bank or logistics relationships that may be named publicly
- Destination markets served to date
If you are evaluating us as a counterparty, ask for any of these directly during buyer qualification. We would rather answer “we cannot evidence that yet” than have you discover it later.
Questions
On compliance
Are you OECD certified?
Will you complete our KYC pack?
Who issues the assay certificate?
Can I confirm your licence position independently?
Verify: This page describes Kenyan procedure as published by regulators and legal commentators. It is not legal advice. Confirm the current position for your transaction with qualified counsel in Kenya and in your destination jurisdiction.
Next step
Verify us before you transact with us
That is not a slogan. Ask for our licence position, our entity details and our banking details during qualification, and confirm each of them at source.
Monday to Friday, 08:00–17:00 East Africa Time (UTC+3)