Precious Metal Dealers
According to the Financial Crimes Enforcement Network (“FinCEN”), dealers in jewels, precious metals, or precious stones are defined as “financial institutions” under the Bank Secrecy Act (BSA). To better protect those who deal in jewels, precious metals, and precious stones from potential abuse by criminals and terrorists, section 352 of the USA PATRIOT ACT requires dealers in precious metals, stones or jewels to establish anti-money laundering programs. The characteristics of jewels, precious metals, and precious stones that make them valuable also make them potentially vulnerable to those seeking to launder money, so it is important that dealers have strong protections in place for them and their clients.
Bates assists dealers and firms in developing and strengthening their BSA/AML/OFAC programs to manage compliance risks and promote best practices for the industry.