We were asked in a recent BSA audit, how we identify these dealers that are required to have an AML Program. So far we just have small Mom and Pop jewelry stores, however, we are growing rapidly and need to be prepared for a customer that qualifies. But the qualifications are very complex. That was why I was hoping someone had encountered this before and could offer advice. From the C.F.R..............
1027.210 Anti-money laundering programs for dealers in precious metals, precious stones, or jewels.
(a)Anti-money laundering program requirement.
(1) Each dealer shall develop and implement a written anti-money laundering program reasonably designed to prevent the dealer from being used to facilitate money laundering and the financing of terrorist activities through the purchase and sale of covered goods. The program must be approved by senior management. A dealer shall make its anti-money laundering program available to the Department of Treasury through FinCEN or its designee upon request.
(2) To the extent that a retailer's purchases from persons other than dealers and other retailers exceeds the $50,000 threshold contained in § 1027.100(b)(2)(i), the anti-money laundering compliance program required of the retailer under this paragraph need only address such purchases.