Regulatory Alerts2005-06-09
Added
Anti-Money Laundering Programs for Dealers in Precious Metals, Stones, or Jewels
FinCEN issues an interim final rule defining 'dealer' as a U.S. person engaged in the purchase and sale of more than $50,000 in covered goods, requiring such entities to develop and implement written anti-money laundering programs. The rule establishes specific program elements including internal policies, a compliance officer, employee training, and independent audits, while explicitly excluding pawnbrokers and most retailers from the definition. The requirement for dealers to implement these programs becomes applicable on January 1, 2006, or within six months of becoming a dealer, whichever is later.
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