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AML program

Also called anti-money laundering program, anti-money-laundering program

An AML program is the written anti-money-laundering programme that federal rules require of dealers in precious metals, stones, and jewels who meet the rules' thresholds.[1]

It has to include risk-based policies and controls, a designated compliance officer, ongoing training, and independent testing.[1]

Whether your business is covered depends on its activity in covered goods. The federal guide explains the test, and this is an area where a professional opinion is worth having.

A programme on paper isn't enough on its own; it's expected to be followed, with records showing the training, reviews, and testing actually happened.

Related terms

Read more

Compliance guideFederal rules for watch dealers: cash reporting, AML, and tax

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Pages on this site that use the term.

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Sources

  1. eCFR 31 CFR 1027.210 (Anti-money laundering programs for dealers in precious metals; precious stones; or jewels). (a)(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 terrorist financing through the purchase and sale of covered goods; THE PROGRAM MUST BE APPROVED BY SENIOR MANAGEMENT; and the dealer SHALL MAKE IT AVAILABLE TO THE DEPARTMENT OF TREASURY THROUGH FINCEN OR ITS DESIGNEE UPON REQUEST. (a)(2) where a RETAILER's purchases from persons other than dealers and other retailers exceed the $50;000 threshold in 1027.100(b)(2)(i); THE PROGRAM NEED ONLY ADDRESS SUCH PURCHASES. (b) MINIMUM REQUIREMENTS - the program shall (1) incorporate POLICIES; PROCEDURES AND INTERNAL CONTROLS based on the dealer's own RISK ASSESSMENT; taking into account the types of products bought and sold; the nature of customers; suppliers; distribution channels and geographic locations; THE EXTENT TO WHICH THE DEALER TRANSACTS OTHER THAN WITH ESTABLISHED CUSTOMERS OR SOURCES OF SUPPLY; and whether payment is routed to or from jurisdictions identified as state sponsors of terrorism; designated non-cooperative; or subject to special measures under 31 U.S.C. 5318A; and (b)(1)(ii) shall include provisions for MAKING REASONABLE INQUIRIES to determine whether a transaction involves money laundering and FOR REFUSING TO CONSUMMATE; WITHDRAWING FROM; OR TERMINATING SUCH TRANSACTIONS. Stated indicators include (A) UNUSUAL PAYMENT METHODS SUCH AS THE USE OF LARGE AMOUNTS OF CASH; multiple or sequentially numbered money orders; traveler's checks or cashier's checks; OR PAYMENT FROM THIRD PARTIES; (B) UNWILLINGNESS TO PROVIDE COMPLETE OR ACCURATE CONTACT INFORMATION; financial references or business affiliations; (C) ATTEMPTS TO MAINTAIN AN UNUSUAL DEGREE OF SECRECY; such as a request that NORMAL BUSINESS RECORDS NOT BE KEPT; (D) purchases or sales UNUSUAL FOR THE PARTICULAR CUSTOMER OR SUPPLIER; and (E) purchases or sales NOT IN CONFORMITY WITH STANDARD INDUSTRY PRACTICE. (2) DESIGNATE A COMPLIANCE OFFICER responsible for effective implementation; updating the program; and ensuring appropriate personnel are trained. (3) provide for ON-GOING EDUCATION AND TRAINING. (4) provide for INDEPENDENT TESTING commensurate with the risk assessment; WHICH MAY BE CONDUCTED BY AN OFFICER OR EMPLOYEE SO LONG AS THE TESTER IS NOT THE DESIGNATED COMPLIANCE OFFICER OR A PERSON INVOLVED IN THE OPERATION OF THE PROGRAM. (c) a dealer must implement a compliant program on or before the later of January 1 2006 or SIX MONTHS AFTER THE DATE THE DEALER BECOMES SUBJECT to the requirements — retrieved 2026-09-23