I have read the regs but would like some clarification on how I should handle a jewelry store that sells large quantities of gold. They sell over $50,000 so they are considered to be a dealer. Does this mean they are only required to have a BSA program or are they required to register for any reason?

We already monitor the activity and they are coded as high risk but I want to be sure there isnt anything further I need to do.

I'd make sure that the store's owners are aware of the existence of 31 CFR Part 1027 and the requirement that they have an AML program. Don't try to provide legal advice for them, though. Tell them to discuss any questions about their obligations under Part 1027 (and under other parts of FinCEN's regulations that are cross-referenced within Part 1027) with their attorney.

Thanks John! It's always nice to have input from the experts.