The Singapore PSPM ACT
CACHE has been granted license number PS20190001508 under the Precious Stones and Precious Metals Dealers (Prevention of Money Laundering and Terrorism Financing) Act (PSPM Act) passed by Singapore Parliament on February 11th 2019 in line with Financial Action Task Force (FATF) recommendations.
PSPM is enforced by the Ministry of Law, which ensures that Singapore's legal infrastructure is clear, efficacious and transparent. The Ministry of Law is also the agency behind the Singapore Convention on Mediation which was recently adopted by the United Nations as a means to settle international trade disputes.
The PSPM Act encompasses physical bullion tokenization and ensures consistent AML/CFT standards are applied when physical gold is bought, sold, tokenized or redeemed by CACHE.
CACHE Operational Scope
CACHE, although permitted to do so by the PSPM act, has elected not to sell tokens directly to or buy tokens directly from the general public and instead only acts as a tokenization and redemption gateway. This policy allows for better scalability, more efficient compliance and helps to overcome some of the key logistical challenges inherent in gold backed tokens.
CACHE therefore does not accept fiat currency or cryptocurrencies from the general public. The only services CACHE offers to the general public are:
- Deposit of branded gold into CACHE vaults for tokenization
- Redemption of tokens for branded gold from CACHE vaults
By concentrating on its core competencies and partnering with reputable bullion dealers to allow their customers to deposit gold for tokenization, CACHE will harness existing industry processes and compliance controls to provide far better scalability than could be accomplished by recreating all of these functions in-house.
CACHE works closely with its approved liquidity and storage providers to optimize tokenization turnaround times and to maximize CACHE Gold liquidity at or near the spot gold price.
CACHE AML/CFT Policy
A verified CACHE Gold account is required to deposit gold or redeem CACHE Gold tokens. Account verification occurs according to the CACHE Compliance Manual which adheres to PSPM requirements as well as international best practices for AML/CFT.
CACHE screens for high risk factors such as politically exposed persons and jurisdictional risk. CACHE conducts a risk assessment and classification on every account holder. CACHE participating vaults must have their own AML/CFT compliance framework. Finally, CACHE has conducted an independent legal assessment by a law firm in Singapore which has ascertained that CACHE Gold tokens are not securities.
For bullion provenance assurance, CACHE leverages both vault and liquidity provider gold provenance controls, ensuring industry best practices are adhered to. Furthermore, through GramChain, CACHE implements additional packaging, transparency and tracking standards as well as tighter sourcing controls which can be publicly verified on the GramChain® explorer.