• Jewellers

    Jewellers are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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What are the ML/TF Risks?

Jewellers are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism as jewellery can be used to store value and a means of exchange.
Jewellers and jewellery may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CFT measures.
The Money Laundering and Terrorism Financing (ML/TF) risks associated with jewellers include:
  • Buying and selling high-value assets is attractive for criminals because such transactions can avoid interaction with the financial sector. Many such assets may be easily hidden and can be transferred to third parties with limited documentation;
  • Transaction methods for jewellery can range from anonymous exchanges of stones or nuggets to government-regulated deals and international transactions conducted through the financial system;
  • Jewellery can also be readily purchased anonymously for cash, easily transported internationally, and later sold for cash, with their value increasing over time;
  • The purchase of jewellery can disguise the real amount of money laundered because a ‘normal’ market price can be hard to establish;
  • The value of the jewellery can be misrepresented by either under or over-valuation to disguise the amount of criminal income laundered through its purchase; and
  • Jewellery also carries an added ML/TF risk because individual items may be small, very high in value, and easily transportable, offering criminals the opportunity to transfer value within or between countries in a manner which minimises the chance of detection.

Jewellers must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for the jewellery industry.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

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