Important: AML Programs! Any advice?

[Midlands]

This forum is the only place where I can ask this question and hopefully get some answers. (Mod: Feel free to move this post to any category. I put it here because it's the most popular one and hopefully reaches the most people.)

So, due to a call from a large client, and a convergence of other circumstances, I just decided to start looking at the laws surrounding AML (Ani-Money Laundering) Programs.

Every gold buyer is required to have an AML program. The risk of not having one includes enough fines to put me in debt forever.

So I looked around and found some info at different sites. But the only ready-made solution or service is JVC "JewelrPac" program. It's $750 for the first year. But then they say it has to be tested yearly, which costs like $2500!!!

What are you other gold buyers doing out there? (I've been blissfully ignorant of the actual details before now.)
Anything cheaper than this?
Is annual testing really necessary?
What will I even have to put in my policies? (Everybody requires payment before you find out. It's like "We have to pass the bill before we can found out what's in the bill!")

Thanks for any info.

 

[Yggdrasil]

This forum is the only place where I can ask this question and hopefully get some answers. (Mod: Feel free to move this post to any category. I put it here because it's the most popular one and hopefully reaches the most people.)

So, due to a call from a large client, and a convergence of other circumstances, I just decided to start looking at the laws surrounding AML (Ani-Money Laundering) Programs.

Every gold buyer is required to have an AML program. The risk of not having one includes enough fines to put me in debt forever.

So I looked around and found some info at different sites. But the only ready-made solution or service is JVC "JewelrPac" program. It's $750 for the first year. But then they say it has to be tested yearly, which costs like $2500!!!

What are you other gold buyers doing out there? (I've been blissfully ignorant of the actual details before now.)
Anything cheaper than this?
Is annual testing really necessary?
What will I even have to put in my policies? (Everybody requires payment before you find out. It's like "We have to pass the bill before we can found out what's in the bill!")

Thanks for any info.

Welcome to us.
I moved it to debates and discussions.
I'm not in US so I have as such not much to say regarding your topic.
The need for AML, I think, goes for professional buyers/sellers.

 

[Martijn]

This forum is the only place where I can ask this question and hopefully get some answers. (Mod: Feel free to move this post to any category. I put it here because it's the most popular one and hopefully reaches the most people.)

So, due to a call from a large client, and a convergence of other circumstances, I just decided to start looking at the laws surrounding AML (Ani-Money Laundering) Programs.

Every gold buyer is required to have an AML program. The risk of not having one includes enough fines to put me in debt forever.

So I looked around and found some info at different sites. But the only ready-made solution or service is JVC "JewelrPac" program. It's $750 for the first year. But then they say it has to be tested yearly, which costs like $2500!!!

What are you other gold buyers doing out there? (I've been blissfully ignorant of the actual details before now.)
Anything cheaper than this?
Is annual testing really necessary?
What will I even have to put in my policies? (Everybody requires payment before you find out. It's like "We have to pass the bill before we can found out what's in the bill!")

Thanks for any info.

Good administration and evidence gathering I guess.
Make copies of ID cards, pictures of purchased goods, dates names signed off transfer sheets, hold on to your material for some time, report any questionable transactions to authorities to be checked for red flags?
The better system of registration you have, the more you will scare off criminals.
Once you processed a batch of criminal origin, you could be forced into a maffia like organization.

 

[Midlands]

Yes, it's required for all "dealers", which FinCEN categorizes as anybody who buys or sells $50,000 of precious metals per year. (That's not even profit--just buying or selling.)

 

[4metals]

Yes, it's required for all "dealers", which FinCEN categorizes as anybody who buys or sells $50,000 of precious metals per year.

You hit that number buying a kilo of 14 karat scrap. I haven't dealt with AML since the laws came to prominence after 9/11 so they were simpler then. Back then all we had to do to comply was have the social security number and information of the customer you dealt with and we kept a photo of the scrap for good measure. It was legal to deal cash as long as you recorded that information. To pay $750 for software that needs annual testing for $2500 seems absurd. That level of AML seems over the top for a gold buyer of small to moderate scale.

If nothing has changed you should write up your policy and provide samples of record-keeping and contact your local police department. Show them what records you will keep and find out how long you have to hold the metals if it is jewelry to melt. For a gold buyer or small refiner I think the police can tell you if your approach is sufficient.

Sounds to me like a few companies are marketing something way in excess of what you need. The original intent of the AML was to find out who was dealing cash and follow the money. For a refiner, the dispenser of the cash, being able to tell the authorities the information about the folks selling you the metals should give them all they need to go to the seller and follow the money. Background checks for all of the gold sellers you deal with is what these AML "must have" programs do is for the big players.

 

[Midlands]

You hit that number buying a kilo of 14 karat scrap. I haven't dealt with AML since the laws came to prominence after 9/11 so they were simpler then. Back then all we had to do to comply was have the social security number and information of the customer you dealt with and we kept a photo of the scrap for good measure. It was legal to deal cash as long as you recorded that information. To pay $750 for software that needs annual testing for $2500 seems absurd. That level of AML seems over the top for a gold buyer of small to moderate scale.

If nothing has changed you should write up your policy and provide samples of record-keeping and contact your local police department. Show them what records you will keep and find out how long you have to hold the metals if it is jewelry to melt. For a gold buyer or small refiner I think the police can tell you if your approach is sufficient.

Sounds to me like a few companies are marketing something way in excess of what you need. The original intent of the AML was to find out who was dealing cash and follow the money. For a refiner, the dispenser of the cash, being able to tell the authorities the information about the folks selling you the metals should give them all they need to go to the seller and follow the money. Background checks for all of the gold sellers you deal with is what these AML "must have" programs do is for the big players.

I know it, but nonetheless I'm considered a dealer. And all dealers are required to have a plan, appoint an officer, get training (found some cheap options online, which is probably good learning for this business anyway), and have the policy "tested periodically".

I'm not paying $750 for a silly program, but I'm especially not paying $2k for somebody to be a secret shopper. So I'm just wondering if other dealers out there (pawn shops, etc.) are observing these laws, and how.

 

[4metals]

Don't rule out talking to the police. If your purchases include photos of the jewelry share that with them as well. If there is ever a large theft or even a series of small burglaries the police will appreciate knowing where it was sold, even if it is long gone your records will be useful. If what you tell them and show them is not sufficient for AML regulations they will tell you.