Dealers in precious metals and stones are singled out by the FATF/GAFI at specific high risk from money launderers. This risk is underlined by the US FinCEN who flag the potential use of ultra-high value and portable precious metals and stones by criminals and terrorists.
Precious metals and stones dealers need to have a robust AML framework designed, implemented and monitored. The key components of an AML framework include:
- Compliance Staffing – experienced and trained personnel to design, implement and operate AML controls.
- Policies/Procedures/Controls – designed to prevent and/or identify potential money laundering.
- AML Resourcing – the implementation and use of technology and reference data appropriate to the firm’s specific risk.
- Staff Training – ensuring that appropriate training is planned and delivered to all staff.
- Monitoring – periodic testing of the effectiveness of the procedures and controls implemented.