Patriot Act Compliance

USA PATRIOT ACT ANTI-MONEY LAUNDERING PROGRAM

Background information / What the law requires of us - and you.


After September 11, 2001, the U.S. Congress enacted a series of requirements and authorizations intended to protect against money laundering to help finance further acts of terrorism, including Section 352 of the USA Patriot act, which requires that all “financial institutions” create and implement an anti-money laundering (AML) program. Subsequent modifications to the original draft of the Bank Secrecy Act of 1970 which defines what/whom is classified as a “financial institution” have gone on to include “dealers in precious metals, stones or jewels.”

Recognizing that a company is most familiar with it’s own operations, the U.S. Treasury Office of Foreign Assets and Control has allowed each required company to develop and implement their own AML Program. Certain basic customer identification information is required in all AML programs, while additional background and banking information with whom we do business may also be required.

If you or your company operates in the capacity as a “dealer in precious metal, jewels or stones’then your activities do indeed fall within the definition of “financial institution” as stated above. The information we are requesting you to provide us with is solely for the internal use of our companies AML Compliance Officer only and is not being collected to share with any government agencies.

Certain businesses may be exempt from being required to implement their own formal AML Programs, at least for the time being. This currently may include some retail jewelers, manufacturers or wholesalers (especially those dealing with less than $50,000 annually) as well as those dealing strictly in silver or precious metals containing less than 50% gold by weight. The final form of “the act” as it pertains to Pawnbrokers is still being developed by Treasury with no final date of completion announced.

As a dealer, processor and refiner of precious metals Stebgo Metals has, since January 1, 2006 been operating under the guidelines of a formal anti-money laundering program which requires that we accumulate and maintain certain information on all companies or individuals with which we do business. The extent that what information is required is typically going to be linked to the risk assessment for each individual customer as detailed by the written program or subjectively determined by the AML Compliance Officer.