Each service stands alone, and they fit together into a full program build. We use AI and our own OFAC software to keep the cost down and the accuracy up, and we build every program for your team to administer in-house. Most clients start with an applicability review, because it decides the scope of everything else.
We start with the question most programs skip: which rules actually reach your business. We apply the dealer definition to your purchase and sale volumes, test whether the retailer exception helps you, confirm which of your products are covered goods, and read your existing program line by line.
You receive: a written scoping memo and a marked-up copy of your current program.
A dealer's program has four required parts. Its policies, procedures, and internal controls must rest on a risk assessment, and the program must be approved by senior management and available to FinCEN on request.
Built on an assessment of the products you sell; your customers, suppliers, and distribution channels; and the geographic locations involved. For purchases, we look at suppliers in higher-risk jurisdictions, unusual payment methods, and metal offered below market.
1027.210(b)(1)A designated person responsible for day-to-day compliance, with a written charter, authority, and escalation path.
1027.210(b)(2)Training for every employee whose role touches customers, transactions, or metal, sized to their roles.
1027.210(b)(3)Testing by someone other than the compliance officer. The rule does not set a frequency; we recommend annually.
1027.210(b)(4)We also write the operating procedures that sit under the program: Know Your Customer steps sized to a dealer (not a bank CIP), red-flag review, the escalation path, voluntary SAR decisions, and record retention.
You receive: a board- or management-ready program, a documented risk assessment, operating procedures, and the Regulatory Basis Addendum.
Sanctions compliance applies to every U.S. person, with no dollar threshold and on a strict liability basis. We build a program on OFAC's five-component framework and give your team a structured way to work every alert.
The program runs on RegSmart's proprietary OFAC software, designed for precious metals and jewelry dealers, so your team can administer it in-house.
Dealers file Form 8300 when they receive more than $10,000 in cash in one transaction or in related transactions. The rules on what counts as cash, which includes certain cashier's checks, money orders, and traveler's checks in some sales, and on when separate payments must be aggregated, are where dealers most often miss a filing.
Many dealers hire a capable compliance officer with no BSA or OFAC background. We built a ten-module curriculum for exactly that situation. Each lesson produces a real work product, so your new officer learns the job by writing your missing procedures, memos, and checklists.
We test whether your program, as written, matches what your people do. That means sampling transactions and alerts, checking Form 8300 filings against cash receipts, reviewing training records, and checking the program against current regulation. Findings are rated by severity and written so management can act on them.
Depository and custody agreements, platform agreements, and supplier contracts carry compliance terms that can quietly expand your obligations: sanctions representations, information-sharing duties on short deadlines, warranties that no law prevents disclosure of customer information, and freeze rights over customer metal. We review these terms against your program and the law so the contract and the program say the same thing.
Banks that serve dealers want evidence of a real program before they open or keep an account. We prepare a concise package that shows your bank how you assess risk, screen customers, and handle cash, and we can answer its due diligence questionnaire with you.
A fixed-scope project covering services 1 through 5, delivered in the four stages: scope, assess, write, operate. At the end, your team administers the program in-house.
A defined annual or periodic engagement with a written report and a follow-up review of remediation.
A retained relationship for alert escalations, regulatory changes, agreement reviews, and questions from your bank or auditor.
Start with the applicability review. It sets the scope for everything else.