- 30 years of financial industry experience including AML compliance and training, securities firm operations and management
- 15 years of AML compliance advisory and education experience in the financial services industry
- Directed Securities Industry Institute at the Wharton School, University of Pennsylvania and other SIFMA training for member firms
- Faculty for Certified Compliance Regulatory Professional (CCRP) at Lubin School of Business, Pace University, ACAMS CAMS-Audit Certification, IMTC Compliance Certification Course, and ComplianceOnline
- Industry arbitrator for FINRA
- All 7 Best Practices
- Pre-Call Discovery Process
- One-on-One Call with Expert
- Session Summary Report
- Post-Session Engagement
Anti-Money Laundering - Dealers in Precious Metals, Stones, or Jewels
- It is often difficult to understand and monitor the risks inherent to dealers in precious metals, gems and jewelry.
It is critical that a risk assessment be completed to keep up with AML regulations as well as changes in the business or customer activity. A risk-based approach should be built on sound foundations; effort must first be made to ensure that the risks are well understood. As such, a risk-based approach should be based on an assessment of threats. This is true whenever a risk-based approach is applied, at any level.
Developing a risk assessment of a firm's customer market will provide the foundation for designing the compliance program. Both the risk assessment and the compliance program should be reviewed and updated according to risk – no less than annually.
- Dealers in precious metals, gems and jewelry often struggle to keep up with regulatory change.
It's simply not enough to establish an AML compliance program and have a compliance officer manage it. No AML program can remain static. It is a regulatory expectation that AML compliance programs will be modified and updated in response to changes in regulations and the business of the firm.
Designating a compliance officer who is familiar with the regulatory requirements will go a long way to protecting you from regulatory risk. Simply appointing personnel with no experience will not serve you well in the long run.
You must protect your firm from all risk -- reputational, operational, credit and regulatory. Your AML compliance program should inform your overall risk management program.
- Dealers in precious metals, gems and jewelry may not be prepared to demonstrate their AML program to banks.
Banks typically require their dealer-clients to provide a copy of their AML program and policies in order to continue their banking relationship. The U.S. Commerce Department has determined that the jewelry business is “high risk,” triggering certain obligations on banks, including monitoring jewelry and precious metal dealer clients for compliance.
Banks will ask to see dealers' documented AML Program and Policy and may even require the review of the dealer’s independent test report. This will ensure to them that the dealer is meeting its regulatory obligations.
- The AML Program fails to offer adequate training.
An AML compliance program must contain four pillars, which includes policies, procedures and internal controls; designation of a compliance officer; training; and independent testing. Training is a key driver that advances the ability to detect unusual activity. Front-line personnel are often the first point of contact with potential money-laundering and fraud, and it is essential they be educated on red flags common to dealers. Having controls in place that include any red flags or suspicions is the first important step to maintaining an effective AML program.
- Dealers in precious metals, gems and jewelry may be confused as to whether they are subject to regulations.
Regulatory rules apply to “dealers” in “covered goods.” Covered goods include jewels, precious metals and precious stones, and "finished goods" (including but not limited to, jewelry, numismatic items, and antiques) that derive 50 percent or more of their value from jewels, precious metals, or precious stones contained in or attached to such finished goods.