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

Guzema Founder and Creative Director Valeriya Guzema and Co-Owner and CEO Mariana Lenha
EditorsJul 16, 2026
Q&A: Guzema’s Co-Owners On Its US Expansion, 10-Year Anniversary

Valeriya Guzema and Mariana Lenha look back on the last decade and discuss the Ukrainian brand’s first U.S. store.

Main camp at Ekati Diamond Mine
SourcingJul 16, 2026
Ekati to Close, Leaving Canada With One Diamond Mine

The diamond mine, which opened nearly 30 years ago in Canada’s Northwest Territories, is expected to shut down by mid-August.

Necklace from Vhernier’s “Freccia” high jewelry collection
FinancialsJul 16, 2026
Richemont’s Jewelry Sales Soar for the Seventh Quarter in a Row

Jewelry sales for the company, which owns Cartier, Van Cleef & Arpels, Vhernier, and Buccellati, rose 21 percent in the first quarter.

Brought-To-By-Article-Top-Image.jpg
Brought to you by
Wedding Band Trends 2026: Personalization Takes Center Stage

Colored gemstones, artisan finishes, mixed metals, and meaningful details are shaping demand in bridal jewelry.

Lucara diamond
SourcingJul 15, 2026
1,305-Carat Diamond Recovered from Mine in Botswana

The yet-to-be named stone is the 10th diamond weighing more than 1,000 carats to come out of Lucara’s Karowe mine.

Weekly QuizJul 09, 2026
This Week’s Quiz
Test your jewelry news knowledge by answering these questions.
Take the Quiz
Barry Berman
IndependentsJul 15, 2026
New Jersey Jeweler Barry Berman Dies at 81

The founder of Fords Jewelers, Berman is remembered for his love of connecting with his community.

Watches of Switzerland Mall of America store
FinancialsJul 15, 2026
Watches of Switzerland’s US Sales Jump 18%, Declines to Comment on Sale Report

The watch and jewelry retailer had a strong fiscal year despite what its CEO described as a “complex operating backdrop.”

DCA-NJ-article-1872x1052-060826.jpg
Brought to you by
Building the Future of Jewelry Retail: DCA Expands Education, Leadership Development, and Workforce Solutions

DCA is preparing the next generation of professionals by supporting workforce development, leadership growth, and career advancement.

Hamptons Jewelry Show exhibitors Maison Mèrenor, Jochen Leën, Studio Javo
Events & AwardsJul 15, 2026
Hamptons Jewelry Show to Return in July

The open-to-the-public luxury jewelry and timepiece show, in its second year, is slated for July 23-26.

Pomellato Eye of Tanzanite Necklace and Pin-Up Ring
CollectionsJul 15, 2026
Pomellato’s New High Jewelry Is Liberating

Bold color, expressive gem-setting, and sculptural form define the three chapters that make up “Stile Libero.”

Foundrae London Store Showcases
IndependentsJul 14, 2026
Foundrae Opens First Standalone Store Outside US

The New York-based jewelry brand has expanded overseas, opening a store in London’s Mayfair district.

The Retail Smiths Principal Partner and National Jeweler columnist Sherry Smith
ColumnistsJul 14, 2026
Sherry Smith: What Today’s Jewelry Consumer Is Telling Us

Rising revenue does not automatically mean a healthy business, particularly in the current economic landscape, Smith writes.

Mindi Mond New York emerald shoulder duster earrings
TrendsJul 14, 2026
Amanda’s Style File: Shoulder Dusters

These long, fluid drop earrings are sure to catch the eye.

FBI Most Wanted image of Alberto Perez-Elias
CrimeJul 14, 2026
Man Charged in $1M Jewelry Store Heist Lands on FBI Most Wanted List

Alberto Perez-Elias is one of four men charged with robbing a Cape Coral, Florida, jewelry store and is the only one still at large.

Aerial view of Amazon
Events & AwardsJul 14, 2026
Conference on Mining, Sustainability Kicks Off in NYC

Initiatives in Art and Culture is hosting its 16th annual Gold and Diamond Conference, with the theme of “Resilience.”

Stephanie Gottlieb Casual Carats Lab-Grown Dimond and Silicone Rings
Lab-GrownJul 13, 2026
Stephanie Gottlieb Changes Her Mind on Lab-Grown Diamonds

The designer, who once said she’d never sell lab-grown diamonds, debuted two capsule collections designed to be fun and easy to wear.

File photo of the Venetia Diamond Mine in South Africa
SourcingJul 13, 2026
De Beers Announces Potential Layoffs, 2-Year Production Pause at Venetia

The diamond miner and marketer is undergoing another round of cost-cutting measures ahead of its sale by Anglo American.

JIS sign in convention center lobby
Events & AwardsJul 13, 2026
Registration Opens for JIS Fall 2026 Show

The annual trade-only buying event is slated for Oct. 16-19 in Miami Beach, Florida.

“Elements” bracelet best of show AGTA Spectrum 2025
Events & AwardsJul 13, 2026
AGTA Accepting Entries for Spectrum 2026

AGTA also has announced the lineup of judges for the colored gemstone cutting and jewelry design contest’s various categories.

Arena Club Twilight and Eclipse Time Boxes
TechnologyJul 10, 2026
There’s a New Blind Box for Luxury Watches

Collectibles platform Arena Club’s new Time Boxes could contain a Rolex or Patek Philippe watch.

Jade Trau Constellation Plié Collar
TrendsJul 10, 2026
Jade Trau Creates a Constellation of Diamonds

The “Constellation Plié” collar, our Piece of the Week, features diamonds arranged in a constellation of shining stars.

Former De Beers CFO of Brands and Consumer Markets Shaun Wills
SourcingJul 10, 2026
CFO of De Beers’ Consumer-Facing Division Leaves Company

Shaun Wills joined the company in 2024 and was chief financial officer of the De Beers Brands and Consumer Markets division.

Brilliant Earth watches
WatchesJul 10, 2026
Brilliant Earth Expands Into Watches

In honor of its 20th anniversary, the jewelry brand has released a limited-edition collection of Swiss-made timepieces.

Boucheron Human Being Collection Tattoo Necklace
CollectionsJul 09, 2026
Boucheron’s New High Jewelry Collection Is an Ode to the Human Touch

“Human Being” highlights the similarities and differences between us through five sets of jewelry that celebrate fine craftsmanship.

Baume & Mercier watch
WatchesJul 09, 2026
Damiani Group Finalizes Acquisition of Baume & Mercier

Richemont will continue to provide operational services for the watch brand for a period while the group prepares to integrate it.

Joopiter Logo
AuctionsJul 09, 2026
Pharrell Williams’ Joopiter Hires Former Bonhams Exec to Head New Watch Division

Nate Borgelt will lead the digital auction house and content platform’s new division as head of watches.

Enoch Michael
Events & AwardsJul 09, 2026
Halstead Names 2026 Grant Winner

Enoch Platero, founder and designer behind Enoch Michael, is the first Native American jeweler to win the award.

×

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