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

Silvia Furmanovich Horse Mane Earrings, Cece Jewellery Underworld Triptych Necklace, Almasika Invictus Flower Brooch
CollectionsMar 13, 2026
A Trio of Jewels from the 3 Gem Award Nominees for Jewelry Design

Our Pieces of the Week honor the 2026 nominees for the Gem Award for Jewelry Design, Silvia Furmanovich, Cece Fein-Hughes, and Catherine Sarr.

Vera Wang
WatchesMar 13, 2026
Citizen, Vera Wang to Launch Watch Collection

The 24-piece watch collection is set to debut in spring 2027.

Andrea Pooler
SourcingMar 13, 2026
Andrea Pooler Joins Third-Generation Diamond Company as COO

Pooler, who has more than 25 years’ experience in jewelry, is now chief operating officer of Modani Jewels, Soham Diamonds, and SNJ Creations.

TopImageCrop.jpg
Brought to you by
Is This You? Every Jeweler Has This Problem; We Have the Solution.

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

24 Karat Club banquet
MajorsMar 13, 2026
24 Karat Club of New York’s Banquet to Return to Waldorf Astoria

The reopening of the Waldorf Astoria means a homecoming for the industry group’s annual event, which will take place Saturday.

Weekly QuizMar 12, 2026
This Week’s Quiz
Test your jewelry news knowledge by answering these questions.
Take the Quiz
Zoë Kravitz in Jessica McCormack’s Planetary Necklace
CollectionsMar 12, 2026
Jessica McCormack Sends Gold, Gemstones Into ‘Orbit’

McCormack looked to the 19th century’s “golden age” of astronomy when designing her new celestial-themed collection.

David Berdugo
TechnologyMar 12, 2026
Caratwise Launches, Names Former Signet Exec CEO

The new smart design software allows jewelers to configure, price, and confirm a custom engagement ring in real time for in-store customers.

dca-laptop.jpg
Brought to you by
DCA Enters a New Chapter in Jewelry Education

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

Woman working at bruting machine, seal at new Grandview Klein factory in South Africa
SourcingMar 12, 2026
Grandview Klein Opens New Factory in South Africa

The 10,000-square-foot diamond manufacturing facility officially opened in late February and employs 50 people.

26.36 carat round brilliant cut
AuctionsMar 11, 2026
‘Spectacular’ 26-Carat Diamond Going Up for Auction in London

The largest white diamond to come to market in the U.K. in more than a decade, the VVS1, I-color stone is expected to top $1 million.

Cast Compass pendant
TechnologyMar 11, 2026
Cast Jewelry’s Rachel Skelly on Coming Back Online Only

Skelly shares her plans for reimagining the fine jewelry retailer she re-acquired after it faltered last year.

Pyrrha The Space Between Campaign
CollectionsMar 11, 2026
Pyrrha Highlights ‘The Space Between’ In New Collection

The collection takes inspiration from the emotional space between people, moments, and experiences.

Charles London, Mayer and Fran Udell, Mark and Candy Udell
IndependentsMar 11, 2026
From the Jazz Age to the Information Age: London Jewelers Turns 100

In 2026, the jewelry retailer is celebrating a milestone only a small percentage of family-owned businesses survive to see.

Virginia jewelers at charity ball
IndependentsMar 11, 2026
Virginia Jewelers Raise Nearly $30K for Children’s Hospital

The group of jewelers held a jewelry raffle in support of the Children’s Hospital of Richmond at VCU.

Stack of gold bangles on denim
FinancialsMar 10, 2026
Signet Jewelers’ Q4 Sales Fall Flat

The jewelry giant released preliminary results for the fourth quarter and full year on Monday, with final results slated to come next week.

Saks Fifth Avenue door sign
MajorsMar 10, 2026
Saks Global to Close 15 More Stores

The retailer also gave an update on its vendor partnerships.

Julianne Moore
TrendsMar 10, 2026
Messika Names Julianne Moore as Ambassador

The award-winning actress is the “epitome of modern allure,” the brand said.

Sorellina Large Bloom Inlay Pendant
CollectionsMar 10, 2026
Gemstones ‘Bloom’ in Sorellina’s New Collection

The “Bloom” collection draws from the flower power movement of the 1960s and ‘70s with inlay pendants offered in eight colorways.

Constellations Over the Sedona
Events & AwardsMar 10, 2026
Diamond-Studded Painting Shines at RJO Foundation Auction

The unique piece was one of the custom works offered at the foundation's recent silent art auction, which garnered nearly $15,000 in total.

Jake Gyllenhaal as Bulgari Brand Ambassador
TrendsMar 09, 2026
Jake Gyllenhaal Is Bulgari’s Latest Ambassador

Bulgari named Gyllenhaal as its brand ambassador for his embodiment of artistic depth, intellectual curiosity, and warmth.

TJS scholarship winners 2026
Events & AwardsMar 09, 2026
TJS Announces 2026 Scholarship Winners

Awards were given to four students, one apprentice, and an emerging jeweler.

Model wearing diamond necklace and ring
AuctionsMar 09, 2026
Joanna Carson’s Jewels Lead White-Glove Sale

The top jewelry lot of the late model’s estate sale, hosted by John Moran Auctioneers, was an Oscar Heyman & Brothers for Cartier necklace.

Tom Moses
GradingMar 06, 2026
Tom Moses Leaving GIA After Nearly 50 Years

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

Charles & Colvard showroom in Morrisville, North Carolina
Lab-GrownMar 06, 2026
Charles & Colvard Files for Bankruptcy, Citing Price Pressures

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

Zome Solara Earrings
CollectionsMar 06, 2026
Zome’s ‘Solara’ Earrings Embody Celestial Beauty

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

Pomellato’s International Women’s Day “The Price of Freedom” Campaign
MajorsMar 06, 2026
Pomellato’s 2026 IWD Campaign Spotlights Economic Abuse

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

Stock image of shipping containers
Policies & IssuesMar 05, 2026
Tariffs to Increase to 15% This Week, Treasury Secretary Says

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

×

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