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AML Program

Under an interim final rule by the Financial Crimes Enforcement Network (FinCEN), dealers in precious metals, stones, or jewels are required to establish anti-money laundering programs. At a minimum, dealers must establish an anti-money laundering program that covers the following:

  1. Policies, procedures, and internal controls, based on the dealer’s assessment of the money laundering and terrorist financing risk associated with its business;
  2. A compliance officer who is responsible for ensuring that the program is implemented effectively;
  3. Ongoing training of appropriate persons concerning their responsibilities under the program;
  4. Independent testing to monitor and maintain an adequate program.

FinCEN is issuing this regulation to better protect those that deal in jewels, precious metals, and precious stones from potential abuse by criminals and terrorists.


The interim final rule applies to “dealers” that have purchased and sold at least $50,000 worth of “covered goods” during the preceding year. The dollar threshold is intended to ensure that the rule only applies to persons engaged in the business of buying and selling a significant amount of these items, rather than small businesses, occasional dealers, and persons dealing in such items for hobby purposes. “Covered goods” include jewels, precious metals, precious stones, and finished goods (including but not limited to, jewelry, numismatic items, and antiques) that derive 50 percent or more of their value from jewels, precious metals, or precious stones contained in or attached to such finished goods. The interim final rule is final and binding.

As a dealer in precious metals, Allegiance Gold uses all of its commercially reasonable efforts to only source its customers’ precious metals from companies that comply with FinCEN regulations. Additionally, Allegiance Gold has an express policy against aiding and abetting in the act of money laundering or facilitating any illegal acts governed by the USA Patriot Act or otherwise.


By agreeing to Allegiance Gold’s terms and conditions and consummating a transaction, each customer represents and warrants to Allegiance Gold that:

  1. The customer is in compliance with the USA Patriot Act;
  2. None of the funds being used to consummate the transaction were derived from or related or connected to money-laundering, terrorism, or any other illegal or illicit activity;
  3. The transaction is not a scheme, or part of a scheme, involving or in support of terrorism, money-laundering or any other illegal or illicit activity.


Allegiance Gold, at all times, reserves the right to require the customer to provide supporting information and documentation in support of the preceding representations and warranties or to ensure compliance with FinCEN regulations. Allegiance Gold maintains an active Anti-money Laundering Program and has designated one of its executive team members as a compliance officer, elected yearly, to actively monitor sales activity, train staff, and monitor changes to regulations.

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