Events & AwardsAug 19, 2021
JVC’s Annual Luncheon Will Be In-Person Again in JanuaryEvents & 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.
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 …
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.
More on Events & Awards
The Latest
SurveysOct 16, 2026
How Inflation, Gas Prices Will Affect Holiday Sales The NRF is expecting holiday sales to increase this year, but consumers and retailers alike are facing Grinch-like headwinds.
CollectionsOct 16, 2026
Christina Puchi’s Earrings Hold the UniverseOur Piece of the Week gathers the planets, represented by a variety of colored gemstones, in a pair of 14-karat yellow gold earrings.
IndependentsOct 16, 2026
Reeds Jewelers Expands, Relocates FlagshipThe New York-based jeweler is moving its Amherst flagship store to a larger location in nearby Snyder.
Brought to you by
Meet Gemology’s Next Generation Microscope: GIA® Gemolite® NXT Professional EditionExperience gemstones with greater precision and comfort than ever before.
MajorsOct 16, 2026
Katy Chen Appointed Executive Vice President of Graff USA Chen, who worked at Cartier and Tiffany & Co., will lead retail sales and operations for the luxury jeweler’s 11 U.S. stores.
Weekly QuizOct 15, 2026
This Week’s QuizTest your jewelry news knowledge by answering these questions.
IndependentsOct 15, 2026
Retailer Hall of Fame 2026: Amy and Elise Greenberg For 40 years, sisters Amy and Elise Greenberg have helmed their 126-year-old family business, leading with appreciation and integrity.
ColumnistsOct 15, 2026
Peter Smith: What Is the Culture REP?It’s a term Smith coined and felt compelled to share following a bad experience with an aborted flight and an unfeeling flight attendant.
Brought to you by
Your Piece Could Be the One Editors Talk AboutSubmit your pieces for a chance to win in this year's competition.
WatchesOct 15, 2026
Stephanie Gottlieb’s New Movado Watches Are Made for Your Wrist StackMovado teamed up with the New York-based fine jewelry designer on a new collection of Movado Museum Velura watches.
SourcingOct 15, 2026
Signet Jewelers, Richemont May Join Bidder for De Beers, Report SaysThe two companies are reportedly in talks to join the Global Diamond Consortium, led by former De Beers CEO Gareth Penny, as per Bloomberg.
CollectionsOct 15, 2026
Wolf x Marla Aaron's New Jewelry Box Is for Some (Not All) of Your ThingsThe “Some of the Things” box follows the two larger “Everything” box designs with the look and function of antique sewing and toolboxes.
IndependentsOct 14, 2026
Retailer Hall of Fame 2026: Coleman and Mitchell ClarkFourth-generation jewelers Coleman and Mitchell Clark exemplify the best qualities of their predecessors: humility, modesty, and confidence.
SourcingOct 14, 2026
Manuel Marcial de Gomar, ‘The Emerald Whisperer,’ Dies at 90The gem hunter, whose 70-year career was defined by adventure and exploration, is remembered for his steadfast faith and sense of wonder.
FinancialsOct 14, 2026
LVMH’s Jewelry Brands Turn in ‘Very Good’ Performance in Q3 Tiffany & Co. continued its full-scale store renovation project while Bulgari’s high jewelry collection generated “record-breaking revenue.”
MajorsOct 13, 2026
David Webb Owner Purchases Lugano JewelryThe high-end jewelry retailer was sold to private investment firm Middle West Partners and a group of longtime clients.
Lab-GrownOct 13, 2026
Stephanie Gottlieb Takes Lab-Grown Diamond Collection WholesaleThe jewelry designer has partnered with Sofer Jewelry to distribute her 85-piece lab-grown diamond collection.
IndependentsOct 13, 2026
Retailer Hall of Fame 2026: Sean DunnDunn, this year’s Single-Store Independent inductee, is passionate about innovation and telling the story of natural diamonds.
AuctionsOct 13, 2026
Christie's Geneva To Auction 'Bulgari Pink' DiamondThe 24-carat fancy intense pink diamond ring could fetch up to $18 million at the November sale.
IndependentsOct 13, 2026
Greenwich St. Jewelers’ New Candle Smells Like HomeThe “Island Jewel” candle honors New York City and Puerto Rico and raises money for the island’s water relief efforts.
TechnologyOct 13, 2026
GemFind Is a New JA Member Benefit Partner The partnership will give JA members access to preferred pricing, exclusive benefits, technology solutions, education, and resources.
SurveysOct 09, 2026
These Will Be the 10 Busiest Days for In-Store Shopping This Holiday SeasonStores should expect to see the most customers on Nov. 27, and Christmas week is expected to be hectic too, as Dec. 25 falls on a Friday.
CollectionsOct 09, 2026
Elisa Solomon Collabs With Serendipity 3 on ‘Frozen Hot Chocolate’ CharmThe charm, our Piece of the Week, features brown diamond frozen hot chocolate topped with white diamond whipped cream and a ruby straw.
AuctionsOct 09, 2026
8-Carat Blue Diamond Goes Unsold at UK Jewelry Auction The top lot of Elmwood’s recent fine jewelry sale in London was a 1.84-carat, D color Tiffany & Co. solitaire diamond ring.
WatchesOct 09, 2026
Movado to Sell Majority Stake in Ebel for $66.5MThe watch company agreed to sell a 95 percent interest to a group comprised of F.P. Journe, Chanel, and Swiss watch exec Pierre Jacques.
Policies & IssuesOct 08, 2026
Third Wave of IEEPA Tariff Refunds Begins This round of tariff refunds is for importers that have sued over IEEPA tariffs in the Court of International Trade and won.
CollectionsOct 08, 2026
Brent Neale’s New Collection Goes ‘Back to Basics’It revisits the brand’s most requested silhouettes, from "Pillow"-set necklaces and bracelets to "Signature"-set rings and earrings.
SourcingOct 08, 2026
Ethical Gem Fair Heads Back to BrooklynThe trade-only event includes buying opportunities as well as educational sessions on artisanal mining, the new Paraíba source, and more.
