Compliance, Anti-Money Laundering & Sourcing Policy

Last updated: August 26, 2026

Randolph & Co. Jewelers (operated by H4 Holdings LLC, "Randolph & Co.," "we," "us") is a dealer in precious metals, precious stones, and jewels. We are committed to conducting business lawfully, ethically, and in compliance with applicable U.S. federal law, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and U.S. economic sanctions administered by the Treasury Department's Office of Foreign Assets Control (OFAC).

Anti-Money Laundering (AML) Program

Businesses that buy and sell precious metals, precious stones, or jewels above certain annual thresholds are classified by the U.S. Department of the Treasury as "dealers in precious metals, precious stones, or jewels" under 31 CFR § 1027.100(b)(1). As applicable to our business, Randolph & Co. maintains internal policies and procedures designed to:

• Identify and verify customers involved in large or unusual cash and cash-equivalent transactions
• Detect and respond to red flags associated with money laundering or terrorist financing
• Retain transaction and customer records as required by law
• Train personnel on AML obligations and red-flag recognition
• Independently test the program on a periodic basis

We comply with IRS/FinCEN Form 8300 reporting for cash payments over $10,000 and do not accept structured payments designed to avoid reporting thresholds.

USA PATRIOT Act Notice

To help the government fight the funding of terrorism and money laundering activities, federal law requires certain financial institutions and dealers to obtain, verify, and record information that identifies each customer entering into significant transactions. Consistent with this policy, we may ask for a customer's name, address, date of birth, and other identifying information, and may ask to see a driver's license or other identifying documents, particularly for high-value or custom orders.

Sanctions (OFAC) Compliance

Randolph & Co. does not knowingly transact business with individuals, entities, or countries designated on the U.S. Treasury OFAC Specially Designated Nationals and Blocked Persons (SDN) List or other applicable sanctions or watch lists. Orders that cannot be verified against these restrictions may be delayed, declined, or canceled and refunded.

Responsible Sourcing & Conflict-Free Materials

Randolph & Co. sources diamonds and gemstones from suppliers who represent that their goods are obtained from legitimate sources not involved in funding conflict, consistent with the Kimberley Process Certification Scheme and the applicable warranty language of the World Diamond Council system of warranties. All applicable invoices for natural diamonds include the required Kimberley Process warranty statement. Lab-grown diamonds sold by Randolph & Co. are created in a controlled laboratory environment and are not mined.

Recordkeeping

We retain records of covered transactions, customer identification, and supporting documentation for the period required by applicable federal recordkeeping rules.

Reporting Concerns

If you have a compliance question, believe a transaction requires review, or wish to report a concern, contact our compliance officer:

Brad Randolph, Compliance Officer
Randolph & Co. Jewelers / H4 Holdings LLC
Email: compliance@randolphcojewelers.com

Disclaimer

This page is provided for transparency and general informational purposes and does not constitute legal advice. It summarizes policies Randolph & Co. maintains internally; it does not create any additional legal rights or obligations beyond those required by applicable law.