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

Stock image of shipping containers
Policies & IssuesSep 17, 2026
Tariffs on India Could Increase as Russian Sanctions Bill Heads to Trump’s Desk

The bill has a provision that allows the president to raise tariffs on countries that import Russian oil and gas to as much as 100 percent.

Cynthia Erivo x Zoe Chicco The Chrysalis Capsule Collection Campaign
CollectionsSep 17, 2026
Cynthia Erivo, Zoë Chicco’s Jewelry Collab Is an Ode to Transformation

The “Chrysalis” capsule centers butterfly motifs representing growth, transformation, and the unfolding of who you are.

Graphic for episode 9 of My Next Question featuring Pamela Froman and Remy Sasha
PodcastsSep 16, 2026
Episode 9: Remembering Cindy Edelstein

Two special guests join the podcast to commemorate the 10th anniversary of the designer advocate, mentor, and author’s untimely passing.

1872 x 1052 Gemolite.jpg
Brought to you by
Meet Gemology’s Next Generation Microscope: GIA® Gemolite® NXT Professional Edition

Experience gemstones with greater precision and comfort than ever before.

L’Objet x Jessica McCormack Homeware Collection
CollectionsSep 16, 2026
Jessica McCormack, L’Objet Collab on Homewares Collection

McCormack brings sea-inspired motifs from her “Beaches” collection to L’Objet’s tableware, vanity pieces, and first-ever cutlery set.

Weekly QuizSep 17, 2026
This Week’s Quiz
Test your jewelry news knowledge by answering these questions.
Take the Quiz
Stock image of police cars with flashing lights
CrimeSep 16, 2026
JSA Issues Warning to NJ Jewelers After Rash of Smash and Grabs

Nine New Jersey jewelers have been victims of smash-and-grab robberies this year, prompting JSA to circulate a list of recommendations.

Brian Hood, president of Bromberg & Co.
IndependentsSep 16, 2026
Bromberg & Co. Names New President

Marlin “Brian” Hood, who has been with the store for 20 years, will succeed Ricky Bromberg, who died earlier this month.

Cover.jpg
Brought to you by
Your Piece Could Be the One Editors Talk About

Submit your pieces for a chance to win in this year's competition.

Midas Chain’s House of Midas Bridal Catalog
MajorsSep 16, 2026
Midas Chain Releases ‘House of Midas’ Bridal Catalog

The new bridal catalog features the latest jewelry collections and designs from timeless classics to modern silhouettes.

Florence Pugh Wearing Bulgari at 2026 Primetime Emmy Awards
EditorsSep 15, 2026
2026 Emmys Jewelry: An Either/Or Proposition

Stars wore either a necklace or earrings at 78th Primetime Emmy Awards but rarely both, Natalie Francisco notes.

Technology Therapy Group founder and CEO Jennifer Shaheen
ColumnistsSep 15, 2026
The Levels Your Website Must Clear Before AI Recommends You

Jennifer Shaheen compares this new era of AI-powered SEO to a video game: your website must clear one level before advancing to the next.

Armadani Retail Support Program Marketing Imagery
IndependentsSep 15, 2026
Armadani Launches Retail Support Program for Holiday Season

The program highlights “Made in Italy” fine jewelry with digital merchandising, sales education, and local marketing support.

Signet Jewelers Joan Hilson
EditorsSep 15, 2026
Q&A: Signet Jewelers’ Joan Hilson on Diamond Demand, the Holidays

Hilson, Signet’s chief operating and financial officer, discussed Q2, resurgent natural diamond demand, and why Blue Nile is a standout.

The Retail Smiths Principal Sherry Smith
ColumnistsSep 14, 2026
Sherry Smith: Stop Waiting for December to Save Your Christmas

The stores that have a great December are the ones that made good decisions in August, September, and October, Sherry Smith writes.

The “Pragnell Kimberley Sunshine Diamond,” 22.09 carats and fancy yellow
AuctionsSep 14, 2026
22 Carats of ‘Sunshine’ Are Up for Auction

The 22.09-carat fancy yellow “Pragnell Kimberley Sunshine Diamond” is part of the fall jewelry sale at Heritage Auctions.

Greenwich St. Jewelers Adornos photography exhibit
IndependentsSep 14, 2026
Greenwich St. Jewelers to Unveil Photography Exhibition

“Adornos: Jewelry, Memory & What We Pass Down” honors the jewelry’s importance to New York City’s Latine communities.

Stock image of rough emeralds mined by Gemfields
SourcingSep 14, 2026
Gemfields Sells All Lots at First Emerald Auction in 9 Months

The company’s managing director of sales said the results demonstrate “continued strong demand for commercial-quality emeralds.”

Kealeboga Pule and Black Coffee
SourcingSep 14, 2026
Diamonds Do Good Pledges Support for Eye Care Program

The nonprofit awarded a grant to the Gift of Sight initiative spearheaded by South African musician Black Coffee.

Greenwich St. Jewelers Scattered Sapphire Cigar Band
CollectionsSep 11, 2026
A Sapphire ‘Stardust’ Ring From Greenwich St. Jewelers

The Latine-owned New York jeweler is marking two milestones this year: its 50th anniversary and the 25th anniversary of the 9/11 attacks.

Make A Wish East Tennessee
MajorsSep 11, 2026
The Wishing Place by JTV Opens

The jewelry retail broadcast network has sponsored a new space for Make-A-Wish East Tennessee on its campus in Knoxville.

The Edge logo
Events & AwardsSep 11, 2026
The Edge Awards Scholarships to 2 Young Jewelry Professionals

The recipients were recognized at the 24 Karat Club of the Southeastern United States’ annual banquet.

Steven Lagos and Keith Rolfe
MajorsSep 10, 2026
Lagos Founder Steven Lagos Steps Down as CEO

Keith Rolfe, CFO and COO of Lagos, is now at the jewelry brand’s helm while Steven takes on the role of executive chairman.

Alberto Perez-Elias mugshot
CrimeSep 10, 2026
FBI Offers $50K Reward for ‘Most Wanted’ Fugitive in $1M Jewelry Heist

Alberto Perez-Elias is one of four men charged in the armed robbery of a Cape Coral, Florida, jewelry store and remains at large.

Kat Florence Paraibas
AuctionsSep 10, 2026
Massive Matched Pair of Paraíba Tourmalines Head to Sotheby’s

The “Kat Florence Luminas” will be offered together as one lot and could fetch up to $637,000.

AGTA logo
SourcingSep 10, 2026
AGTA Announces 4 Newly Elected Directors

Four directors were elected to the AGTA board and will serve three-year terms beginning in February.

New Julien’s Auctions CEO Ken Citron
AuctionsSep 10, 2026
Former Sotheby’s, Christie’s Exec Appointed CEO of Julien’s Auctions

Ken Citron joins the celebrity memorabilia-focused auction house ahead of its first week-long series of events in Abu Dhabi.

Blue Nile Ellipse earrings
FinancialsSep 09, 2026
Signet Jewelers to ‘Double Down’ on Blue Nile Amid Strong Sales

The jewelry retailer said it sees opportunity at higher price points, particularly in natural diamonds for bridal and fashion.

×

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