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

An interior shot of the Musee Lalique in Wingen-sur-Moder, France
CrimeAug 06, 2026
Lalique Museum to Remain Closed Following $5M Heist

Museum officials are looking to the public to help cover the “exceptional” costs involved in recovering from the July 5 smash-and-grab.

1872-x-1052-July-ad (2).png
Supplier BulletinAug 06, 2026
Why More Jewelry Retailers Are Hosting Turnkey Estate Buying Events

Sponsored by Stratus Estate Buyers

Claire’s new piercing experience
MajorsAug 06, 2026
Claire’s Revamps Piercing Services for Second Time in Three Years

The overhaul includes enhanced employee safety training and trendy earring styles, including lab-grown diamond studs.

1872-x-1052-July-ad (1).png
Brought to you by
Why More Jewelry Retailers Are Hosting Turnkey Estate Buying Events

Retailers are seeking new ways to attract customers, increase traffic, and create revenue – Estate buying events are a popular solution.

Brilliant Earth Jane Goodall collection rings
FinancialsAug 06, 2026
Brilliant Earth’s Q2 Sales Up 6%, Driven by High-Income Shoppers

The retailer said it had its biggest Mother’s Day ever, with strong demand for higher-priced jewelry.

Weekly QuizAug 06, 2026
This Week’s Quiz
Test your jewelry news knowledge by answering these questions.
Take the Quiz
Handwork: Handcrafted Objects that Made America Book Cover
TrendsAug 06, 2026
New Book on Handcrafted American Objects Highlights Jewelry

“Handwork: Handcrafted Objects that Made America” features historic and contemporary works, including a Diné squash blossom necklace.

Ani Khachian
MajorsAug 06, 2026
AJA East Coast Names Ani Khachian as First Female President-Elect

The Armenian Jewelers Association’s East Coast chapter has also elected its 2026–2027 board of directors.

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.

JCPenney storefront
MajorsAug 05, 2026
Private Equity Firm Wants to Buy 100+ JCPenney Stores

Onyx Partners has submitted a second offer to buy the department stores after its first offer fell through last year.

The Roaring Jewel Martini
IndependentsAug 05, 2026
Atlanta Jeweler Introduces $10K Martini

Solomon Brothers Jewelers has partnered with local cocktail bar Roaring Social on a new martini garnished with a tennis necklace.

Benjamin Siegel of Hamilton Jewelers
IndependentsAug 05, 2026
Another Member of the Siegel Family Joins Hamilton Jewelers

Benjamin Siegel, son of President and CEO Hank Siegel, started working for the family business this week.

Bulgari San Diego Store Exterior
MajorsAug 05, 2026
Bulgari Opens Store in San Diego

The new space features a modern design that blends Bulgari’s Roman heritage with San Diego’s coastal spirit.

Mugshots of four men
CrimeAug 04, 2026
Crew of Thieves Break Into Indiana Jeweler’s Home

Four men were charged in connection with the break-in and accused of stealing $365,000 in cash, jewelry, and designer goods.

André Branch
MajorsAug 04, 2026
Pandora Hires Former Signet Board Member to Lead North American Market

André Branch has more than 25 years of experience with various brands, most recently serving as CEO of Ariana Grande’s cosmetics company.

Gemlok earrings
MajorsAug 04, 2026
Sasha Primak Acquires Gemlok

New York-based atelier Gemlok is best known for creating the innovative “bridge” setting that became popular in the bridal market.

Santana Now Unidad Collection Campaign Imagery
CollectionsAug 04, 2026
Musician Carlos Santana Launches Jewelry Brand

Santana Now's debut collection, “Unidad,” features symbolic motifs as well as pieces of wood from the Woodstock stage.

Stock image of a gavel and books
CrimeAug 03, 2026
Florida Man Gets 15 Years in Trio of Jewelry Store Robberies

The 50-year-old man pleaded guilty earlier this year to robbing two jewelry stores and a pawn shop of more than $700,000 in merchandise.

Spider-Man Citizen watch and pin on a web
WatchesAug 03, 2026
Citizen's New Spider-Man Watch Is a Collector’s Dream

The watch’s dial features an original design by Marvel comics illustrator Adam Kubert.

Chatham Men’s Collection Campaign Imagery
CollectionsAug 03, 2026
Chatham Releases First Men’s Collection

The new collection of lab-grown diamond and colored gemstone jewelry provides a “fresh perspective” on the category, Chatham said.

Pomellato Marvelous Griffe earrings
TrendsAug 03, 2026
Amanda’s Style File: Spinel vs. Peridot

While some August babies are team peridot, the month's time-honored birthstone, others are team spinel, the newer alternative.

Edina Kiss Popsicle Pendant and Karina Choudhrie Ice Cream Charm
TrendsJul 31, 2026
These Pieces of the Week Are Sweet

Edina Kiss’ “Popsicle” pendant and Karina Choudhrie’s “Ice Cream” charm satisfy that summer craving for a sweet piece of jewelry.

Macy’s Herald Square store sign
MajorsJul 31, 2026
Macy’s Iconic Red Shopping Bag Sign Torn Down

The massive billboard has been in the same spot on the department store’s Herald Square flagship store for decades.

Gemfields emeralds
SourcingJul 31, 2026
Gemfields’ H1 Revenue Jumps 72%

The miner’s ruby and emerald auctions brought in a combined $102.9 million.

Stock image of a polished diamond being held by tweezers
SourcingJul 30, 2026
De Beers Sale in ‘Final, Most Challenging’ Phase, Anglo CEO Says

The goal is for the De Beers sale to be finished by the second half of 2026, with the subsequent approvals process expected to take a year.

U.S. Trade Representative Jamieson Greer and Jewelers of America President and CEO David Bonaparte in Washington, D.C.
Policies & IssuesJul 30, 2026
JA Heads Back to Washington as New Wave of Tariffs Takes Effect

David Bonaparte, along with Tim Haake and Ronnie VanderLinden, continue to lobby for tariff exemptions for diamonds, gemstones, and pearls.

Hands pushing shopping cart
SurveysJul 30, 2026
Consumer Confidence Slips in July

Survey respondents were concerned about the rising prices of food and groceries as well as unemployment.

Endiama Commercial Director Elton Escrivão at the 2026 African Mining Indaba
EditorsJul 29, 2026
Q&A: The Past and Future of Angola’s Diamond Industry

Endiama Commercial Director Elton Escrivão knows people have a lot of misperceptions about Angola. He wants to change that.

×

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