Bullion and coin dealers
Online and storefront dealers selling bars, rounds, and coins to retail customers. Typical needs: right-sized KYC, Form 8300, and screening of a large retail customer base on every list update.
Who we serve
Businesses that buy, sell, hold, or move metal, stones, and jewelry.
We work with dealers in precious metals, precious stones, and jewelry, from bullion dealers to retail jewelers, and with the non-bank businesses around them. Some of our clients are dealers with a full BSA program obligation. Others fall outside the dealer definition but still need a sanctions program, or need to fit into a partner's compliance requirements. The first job is always to work out which you are.
DealersPart 1027
Businesses with a BSA program obligation
Precious metals advisory and brokerage firms
Firms that recommend and execute metal purchases for clients, often with storage at a third-party depository. Typical needs: correcting programs built on broker-dealer rules, and coordinating sanctions duties with the custodian.
Retail jewelers
Jewelers selling primarily to the public are retailers under the rule. A retailer that buys more than $50,000 a year in covered goods from the public or foreign sellers becomes a dealer for those purchases. Typical needs: the retailer exception analysis, controls on buying from walk-in sellers, and Form 8300 on cash sales.
Jewelry manufacturers, wholesalers, and importers
Businesses buying and selling jewels and finished jewelry in the trade. Typical needs: covered-goods classification, supplier and import-source due diligence, and sanctions screening of foreign suppliers.
Diamond and gemstone dealers
Dealers in precious stones, loose or set. Typical needs: source and country-of-origin risk, sanctions exposure in the supply chain, and controls on high-value, easily moved goods.
Refiners, recyclers, and gold buyers
Businesses buying scrap, doré, and secondary material, including buy-from-the-public gold buyers. Typical needs: supplier due diligence, source-of-material red flags, and geographic risk on the purchase side.
Adjacent businesses31 CFR ch. V
Businesses that need sanctions compliance, and sometimes more
Depositories and vault operators
A pure storage business may not be a dealer, but it holds property that can become blocked. Typical needs: an OFAC program, blocking procedures for metal in custody, and clear allocation of duties with dealer clients.
Metals platforms and fintech
Apps and accounts that let customers buy, hold, or transfer metal. Typical needs: deciding whether the model is a dealer, a money transmitter, or both, and building the right program for each.
Pawnbrokers
Licensed pawnbrokers are excluded from the dealer definition only for their pawn transactions; buying gold or jewelry outright can still count toward the dealer thresholds. Form 8300 and OFAC apply either way. Check cashing or money order sales can also bring money services business rules into play. Typical needs: a clear map of which federal rules apply alongside state pawn law, and a sanctions program.
Watch and luxury goods sellers
High-value goods sold for cash create Form 8300 obligations, and items that derive at least half their value from precious metal or stones can be covered goods. Typical needs: classification, cash aggregation rules, and screening.
Shippers, insurers, and service providers
Businesses that move or protect metal for others. Typical needs: counterparty screening and contract terms that match their partners' sanctions programs.
Other physical commodity traders
Businesses trading physical commodities outside Part 1027. Typical needs: a stand-alone OFAC program built on the same framework, without an AML program they are not required to have.
Fit
You are likely a good fit if
- Your AML program was adapted from a bank or broker-dealer template
- You have a new compliance officer without BSA or OFAC experience
- Screening alerts are piling up without a consistent way to close them
- Your bank, depository, or a partner has asked to see your program
- You have never had an independent test, or your last one is out of date
Not sure which category you fall into?
That question is the first thing we answer.