Does anyone have a questionnaire that they care to share that will help the frontline (and these types of businesses) understand the information we need in order to determine if the customer needs to produce an AML policy/procedures? The lengthy definitions seem to be the stickler.

We have a similar question on our application for privately owned ATMs, and if answered "yes", the customer needs to complete our questionnaire. I am looking for something similar.

Thanks in advance.

We only ask for AML Policy and Procedures for MSB's. Not Private ATM's, although we do have a questionnaire for them.

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.