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.

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.
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

Moses, who started at GIA’s Santa Monica lab in 1976, will leave the Gemological Institute of America in May.

Increased competition, falling lab-grown diamond and moissanite prices, and the rising cost of gold took a toll on the moissanite maker.

The earrings, our Piece of the Week, feature pink tourmalines as planets orbiting around an aquamarine center set in 18-karat rose gold.

Every jeweler faces the same challenge: helping customers protect what they love. Here’s the solution designed for today’s jewelry business.

“The Price of Freedom” campaign video for International Women’s Day confronts the quiet violence of financial control.


Also, a federal judge has ordered that companies that paid tariffs implemented under the IEEPA are entitled to refunds.

The ever-growing collection, which just expanded with the addition of Olga of Kyiv, features cameos of 12 women from history.

With refreshed branding, a new website, updated courses, and a pathway for growth, DCA is dedicated to supporting retail staff development.

We asked a jewelry historian, designer, bridal director, and wedding expert what’s trending in engagement rings. Here’s what they said.

The “Outlander” star modeled for the digital cover of the magazine’s spring issue, which features a story on her relationship with jewelry.

This year’s annual congress, which will mark the confederation’s 100th anniversary, will take place this fall in Italy.

Beverly Hills was chosen as the location for the brand’s first store, designed as a “private residence for modern monarchs.”

Kering, Apple, and other retailers have reportedly temporarily closed stores in the Middle East region in light of the recent conflicts.

Beth Gerstein discusses the vibe of the new store, what customers want when fine jewelry shopping today, and the details of “Date Night.”

The “Live Now. Polish Later.” campaign features equestrians wearing the brand’s jewels while galloping across the icy plains of Kazakhstan.

The precious metals provider has promoted Jennifer Ashworth to the role.

Nelson will be honored as the inaugural grant winner at the Gem Awards gala on March 13.

Experts from India weigh in the politics, policies, and market dynamics for diamantaires to monitor in 2026 and beyond.

The American precious metals refiner’s day-to-day operations remain the same post-acquisition.

These aquamarine jewels channel the calming energy of the March birthstone.

The “Innovative Design” category and award will debut in the Spectrum division of this year’s AGTA Spectrum & Cutting Edge Awards.

Diamond jewelry was the star of the event formerly known as the SAG Awards.

Consumers were somewhat less worried about the future, though concerns about rising prices and politics remained.

Foerster is this year’s Stanley Schechter Award recipient.

Sponsorships and tickets to the annual fundraising event, set for May 31, are available now.

Chicago police and members of the U.S. Marshals Service tracked down the 35-year-old suspect earlier this week in St. Louis.

Owners of the Ekapa Mine reportedly filed for liquidation about a week after a mudslide trapped five workers who have yet to be found.





















