The Jewelers Vigilance Committee has compiled a list of countries that have laws in place to prevent money laundering in the jewelry industry. The list is available on the JVC Web site.
The United States government generally exempts jewelry retailers from the obligation of implementing anti-money laundering programs, even if the retailers otherwise qualify as “dealers” in “covered goods,” JVC said in a statement. An exception to this general exemption is if the retailer acquires covered goods from foreign countries, in which case the retailer must institute an AML program that assigns a risk level to those transactions.
Many foreign countries, however, have their own AML programs that include trade in precious stones and metals. For this reason, our government allows retailers to assign a relatively low risk to suppliers from those countries—as long as the supplier represents that it is in full compliance with its country’s AML laws.
JVC said that for purposes of evaluating risk, a retailer should determine if its supplier:
* Is situated in a country that has AML laws, and
* That country’s AML laws cover precious metals and stones, and
* The supplier represents that it is compliant with the country’s laws, and
* There are no “red flags” associated with transactions with the supplier, then
* The retailer may assign a low-risk level to transactions with that supplier.
Determining the existence and reach of a particular country’s AML laws must be done on a case by case basis. JVC said it has been able to ascertain that the AML laws of specific countries cover the jewelry industry or some aspect of the industry.