In these unprecedented times, it is more important than ever to educate yourselves and look to experts for ways to keep your business safe. Jewelers Mutual Group is grateful for the Jewelers Vigilance Committee (JVC) as they are a trusted advisor on this topic and an important source to understand the facts.
JVC reports – In addition to the preexisting sanctions on Russia-origin diamonds, the Office of Foreign Assets Control (part of the Treasury Department) recently stated that its prohibitions also apply to Russia-origin gold. Here are three recommendations from JVC to help protect yourself from potential threats.
1. Vet your vendors and suppliers for potential risks
Contact your vendor and supply chain partners and ask them to review their source partners to ensure that their own supply chain is legitimate. Making sure you know exactly where your gems and precious metals are coming from is the best way to ensure you are getting legally sourced materials.
2. Stop doing business with any sanctioned entities
Only purchase gold supplies from companies that have voluntarily submitted to formal supply chain standards. This includes buying from companies that have implemented certification standards or assurances. Check the OFAC Sanctions Search List to make sure you’re not sourcing products from individuals or companies that are on the list. This list does change frequently, so consider re-checking it periodically.
3. Create (or activate) an Anti-Money Laundering (AML) Program
Did you know that any jeweler doing over $50,000 in purchases and sales of covered goods (precious metals, precious gems/jewels, and finished jewelry for which 50% or more of the value comes from precious metals and/or gems) is legally required to have an anti-money laundering (AML) program? If you don’t already have one in place, now is the time to create one. Failure to do so could lead to having your assets frozen, business closed, or even jail time in some extreme cases.
An active AML program not only demonstrates compliance with the law but serves as a first step towards tracking your gold suppliers. Specifically, it helps to “flag” suspicious activity or bad actors in your supply chain via OFAC’s sanction lists. Jewelers Mutual Group, together with Jewelers Vigilance Committee offers the JewelPAC® program to help you build an AML program for your business.
How to create an AML Program in five steps
- Appoint a compliance officer
- Conduct a risk assessment – where is your business at risk for being used for money laundering or terrorist financing?
- Write a program and policy. Outline the action you will take to prevent money laundering.
- Train employees
- Periodically run a test to ensure program is working as intended.
To learn more about the importance of an AML program, visit the JVC website.
Additional resources:
JM Intel Insights: Anti-Money Laundering 101 with JVC President and CEO Tiffany Stevens
JewelPAC program: FAQs
OFAC: Sanctions Search List
OFAC Hotline: 1-800-540-6322
This content is for general informational purposes only and should not be considered legal advice.
