Events & Awards

From Conclave: JVC Shares Anti-Money Laundering Program Tips

Events & AwardsSep 22, 2021

From Conclave: JVC Shares Anti-Money Laundering Program Tips

Plus, jeweler Melissa Quick of Steve Quick Jeweler details what it was like to go through an AML audit.

20210922_Money Laundering.jpg
During a presentation at AGS Conclave in Dallas last week, Tiffany Stevens and Sara Yood of the Jewelers Vigilance Committee and Melissa Quick of Steve Quick Jeweler shared tips on how jewelers can set up and maintain an anti-money laundering program.
Dallas— Attorneys from the Jewelers Vigilance Committee headed to Dallas last week to school AGS Conclave attendees on the do’s and don’ts of creating an anti-money laundering program.

From scouring supplier lists to trade-in exceptions, JVC’s Tiffany Stevens and Sara Yood delved into the details.

And Melissa Quick of Steve Quick Jeweler in Chicago shared her personal experience of being audited as a cautionary tale for other jewelers.

Here are a few important things to keep in mind, per the presentation.

Know the law and if it applies to your business.

Money laundering is the process of making ill-gotten gains appear legal and any jeweler is liable to get tangled in its web.

Anti-money laundering (AML) laws were first enacted in the United States by the Bank Secrecy Act of 1970 and were later expanded to include jewelers by the USA Patriot Act of 2001.

The regulations apply to jewelers who purchase and sell $50,000 or more in “covered goods,” which refer to goods made of precious metal, precious gems, and jewels and jewelry that derive at least 50 percent of their value from those precious materials.

However, retailers who only buy from sellers who are compliant with U.S. anti-money laundering laws do not need to have an AML program in place.

If a retailer buys from a foreign supplier, estate sales, auction houses, government-sponsored sales, or from the public (not including trade-ins), then an AML program should be put in place.

(Regarding trade-ins, AML rules apply if a trade-in leads to a payment to the customer and retailers should ask to see an ID.)

Jewelers should name a compliance officer to take charge of the AML program.

This person needs to be an employee of the company who is knowledgeable about the business, capable of documenting actions related to the program, and has the authority to make decisions on behalf of the company.

Also, be sure all employees are aware of the program and trained on how it works.

If a business is not compliant, following investigations and legal proceedings, regulators could impose two different types of penalties, according to Jewelers of America.

A retailer could face a civil penalty with a fine up to $250,000 or up to two times the amount of the transaction (not to exceed $1 million), or a criminal penalty with a fine up to $500,000 and a maximum of 10 years in prison, or both.

Check on suppliers regularly.

It’s important for jewelers to perform a risk assessment, paying particular attention to suppliers.

The Office of Foreign Assets Control, a division of the U.S. Treasury, publishes a list of individuals and companies owned or controlled by countries U.S. citizens are not permitted to do business with by law.

It also lists individuals, groups and entities, like terrorists and drug traffickers, that are not country-specific. They are called “specially designated nationals” (SDNs) and U.S. citizens must avoid doing business with them as well.

Jewelers can also check the list of sanctions programs and the Financial Action Task Force’s list of non-cooperative countries.

JVC advises retailers to go through their supplier list and spot check regularly to see if any show up on these lists. Customers can be checked as well.

If there appears to be a match, verify before burning that bridge.

Jewelers should keep an Excel file or list to document when the list has been cross-checked.

If an auditor comes knocking, well-kept records could fend them off, or at least buy some time, said Yood.

 Related stories will be right here … 

Be wary of red flags.

Many jewelers have long-standing, trustworthy relationships with their suppliers and customers, but if something feels off,  examine the situation.

For example, if a supplier suddenly wants a jeweler to send payment somewhere other than the usual place, that’s a red flag, said Yood.

When jewelers encounter a red flag, they should speak with the supplier or customer and ask a few clarifying questions.

Make a risk assessment and consult with the AML compliance officer, then decide whether or not to proceed with the transaction and document the decision.

Stop accepting cash payments.

Cash transactions come with their own baggage.

Transactions over $10,000 paid in cash have to be reported to the IRS via a form 8300. Whether it’s one transaction or a related series of transactions, that form needs to be filled out.

A retailer will need a customer’s tax ID and address to fill out that form, so be sure to collect that.

A foolproof way to avoid the problems attached to cash payments is to stop accepting them, said Yood.

“If someone really wants to buy something, they will figure out a way to pay you that is not cash,” she said.

While getting rid of paper money, ditch the paper invoices too, said Yood, noting digital ones are easier to sort through and manage.

Stress test the program.

Those looking to create a program have a few options.

Jewelers can hire an attorney to draft one, purchase JewelPAC, an automated software program from JVC and Jewelers Mutual, or buy JVC’s hard copy AML kit.

Once a program in place, be sure that it works. JVC recommends annual testing by a third-party auditor.

The stress test should include a full review of the AML program and documents as well as a review of three months of transactions.

Ledger entries should be matched to invoices and then to payments to suppliers or from customers.

Yood recommends holding onto all documents for seven years, as per the usual legal standard.

A word from the wise

Melissa Quick shared her experience of being audited with the session attendees, recounting a harrowing tale of nonstop paperwork and hefty legal fees.

The IRS contacted her seemingly out of the blue, showing up just ahead of the holiday season, an inopportune time for any retailer. Thankfully, her lawyer was able to negotiate a postponement until after the holidays.

The auditor dragged Quick along on a 9-month long journey that cost her $25,000 in legal fees.

“I didn’t do anything wrong, but it was a great expense to prove I didn’t do anything wrong,” said Quick.

Time and money aside, the experience was a drain on her mental health.

Quick reached out to JVC for guidance on how she and her lawyer should navigate the auditing process.

Looking to avoid this ordeal again in the future, Quick heeded Yood’s advice and stopped taking cash payments entirely, concluding she’d rather pay the 2.5 percent credit card processing fee and avoid another five-figure legal bill.

She also no longer works with international vendors to lower her risk level.

Quick said she doesn’t know any other jewelers who have gone through this process, though Yood was aware of a few in the Midwest and on the West Coast.

The likelihood of an audit is low, said Yood, but it’s always good to be prepared.

The Latest

My Next Question, Episode 5: Amanda Gizzi, Michelle Graff, Frank Everett
PodcastsMay 21, 2026
Episode 5: Sotheby’s Frank Everett Puts the Auction Market in Perspective

Everett covers colored stones’ surging popularity, the mellow return of the “Mellon Blue,” and his “The Devil Wears Prada” doppelgänger.

Springer’s Jewelers new flagship rendering
IndependentsMay 21, 2026
Springer’s Jewelers’ New Flagship Will Serve Next-Gen Luxury Shoppers

Fourth-generation CEO Lilly Mullen wants to emphasize experience, connection, and personalized service.

WFDB International Summit
SourcingMay 21, 2026
Botswana, Angola Join WFDB

The addition of the diamond-producing countries as nation affiliated members broadens the federation’s global representation, WFDB said.

PG-05-SHOT-2-LUCIDA.033 1.png
Brought to you by
All Eyes on Gold Prices. Alternatives to Look For. And What to BEWARE of in Vegas

As gold prices rise, today’s retailers are looking for alternatives at prices that will appeal to wider audiences.

Jewelry scam flyer and police officer handing flyer to elderly man
CrimeMay 20, 2026
NYPD Warns of Jewelry Swap Scams Targeting Seniors

The NYPD is warning elderly New Yorkers to keep their jewelry hidden when walking outside to avoid being a target.

Weekly QuizMay 14, 2026
This Week’s Quiz
Test your jewelry news knowledge by answering these questions.
Take the Quiz
New Adornment & Theory jewelry store in West Town, Chicago
IndependentsMay 20, 2026
Adornment & Theory’s New Store Feels Like Home

Designer Viviana Langhoff has realized her dream of owning a space for her Chicago jewelry store that looks and feels like her brand.

Morgan P. Richardson
Lab-GrownMay 20, 2026
Savannah Friedkin Jewelry Names New CEO

Former Stephanie Gottlieb Fine Jewelry executive Morgan P. Richardson is joining the lab-grown diamond jewelry brand.

1872x1052-NextGem-2026-National-Jeweler-Advertorial.jpg
Brought to you by
How Modern Training Is Becoming a Competitive Advantage for Jewelry Retailers

With the trade and customer trust in mind, GIA® developed NextGem™ – on-demand training designed specifically for retail.

Audemars Piguet x Swatch white Royal Pop watch
WatchesMay 19, 2026
Here’s the AP x Swatch Pocket Watch That Caused Pandemonium

The $400 pocket watch is a blend of Audemars Piguet’s iconic eight-sided Royal Oak and Swatch’s unserious Pop watches from the ‘80s.

Chris Ploof Modern Electrum Collection Milgrain Rows and Diamonds Ring
CollectionsMay 19, 2026
Chris Ploof’s New Collection Makes an Ancient Medal Modern

With gold prices on the rise, the “Modern Electrum” collection uses an alternative, non-tarnishing metal alloy composed of gold and silver.

Ellen and Michael Fruchtman
IndependentsMay 19, 2026
Ellen and Michael Fruchtman Retire, Sell Marketing Agency

Fruchtman Marketing has new owners, Erin Moyer-Carballea and Manuel Carballea, and will relocate to Miami.

Peter Smith and National Jeweler contributor
ColumnistsMay 19, 2026
Peter Smith: The (Mostly) Immutable Sales Truths

In a column for the 2026 State of the Majors issue, Smith lists 10 time-tested principles about sales that still ring true.

Edahn Golan, Tenoris co-founder and National Jeweler contributor
ColumnistsMay 18, 2026
Edahn Golan: What a K-Shaped Economy Means for Fine Jewelry

In a column for the 2026 State of the Majors issue, Golan spells out how the growing economic divide in the U.S. is reshaping the market.

Foundrae Limitless Expansion of Joy and Hope Collection Campaign Imagery
CollectionsMay 18, 2026
Foundrae’s New Collection Taps Into Joy

The “Limitless Expansion of Joy and Hope” collection evokes summer through colored gemstones and motifs of butterflies and florals.

Inchiquin emerald
CollectionsMay 18, 2026
Hancocks London Acquires Historic ‘Inchiquin’ Emerald

The jewel, circa 1890, is from the late Victorian era and was owned by descendants of the last high king of Ireland.

JCK Industry Fund Logo
Events & AwardsMay 18, 2026
Here Are the 2026 JCK Industry Fund Grant Recipients

This is what the nine recipients plan to do with the funds.

John Wayne Signet Ring
AuctionsMay 15, 2026
American Collector Ponies Up Almost $17K for John Wayne’s Ring

The Western star’s 14-karat gold signet ring sold for six times its low estimate following a bidding war at U.K. auction house Elmwood’s.

MJSA Education Foundation and Jewelers of America
Events & AwardsMay 15, 2026
JA, MJSA To Sponsor Roundtable at TJS

The discussion, "Rebuilding the Jewelry Workforce," will take place on Saturday, May 16, in Troy, Michigan.

Three gold rings set with yellow- and brown-hued diamonds
SourcingMay 15, 2026
State of Diamonds: The Way Forward for Natural Diamonds

The jewelry industry is reassessing its positioning as Gen Z reshapes the retail landscape and lab grown continues to gain market share.

Matching pair of Type IIa, D-color diamonds
AuctionsMay 14, 2026
White Diamonds Lead Sotheby’s Auction, Blue Diamond Does Not Sell

A matching pair of 18.38-carat, D-color diamonds from Botswana’s Jwaneng mine sold for $3.3 million, the top lot of the jewelry auction.

DeBeeers_Bridal_Display_Dune_1872x1052.jpg
Supplier BulletinMay 14, 2026
A Diamond Is Forever Continues Desert Diamonds – Bridal Reinvigorated

Sponsored by A Diamond Is Forever

Faceting Apprentice gem cutting school
SourcingMay 14, 2026
State of Colored Stones: The Spirit of Young American Gemstone Cutters

The next generation of lapidarists are entrepreneurial, engaged online, and see the craft as a means for artistic expression.

Ocean Dream diamond
AuctionsMay 14, 2026
‘Ocean Dream’ Makes Waves at Christie’s, Fetching $17M

It was the second auction appearance for the fancy vivid blue-green diamond, which sold for $7.8 million at Christie’s Geneva 12 years ago.

Stock image of police cars with their lights on
CrimeMay 14, 2026
Second Man Arrested in Florida Pawn Shop Shooting

Members of the U.S. Marshals Task Force took a 22-year-old man into custody. He was charged with tampering with evidence.

Stock image of crime scene with police cars and crime scene tape
CrimeMay 13, 2026
JSA’s 2025 Crime Report Shows ‘Concerning’ Rise in Violence

While the overall number of crimes was down, there were more incidences in which robbers pulled out guns, mace, or rammed cars into stores.

Jack Sutton Jewelers
IndependentsMay 13, 2026
New Orleans Jeweler Closing Canal Place Store

Jack Sutton Fine Jewelry is closing its store inside the downtown shopping center after 40 years in business.

Winston Red Diamond painting by Reena Ahluwalia
SourcingMay 13, 2026
Smithsonian Acquires ‘Winston Red’ Diamond Painting

Reena Ahluwalia’s painting of the rare red diamond is the first contemporary painting to join the National Gem Collection.

×

This site uses cookies to give you the best online experience. By continuing to use & browse this site, we assume you agree to our Privacy Policy