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RAPAPORT... The Jewelers Vigilance Committee (JVC) is reminding jewelers that the deadline for implementing the IRS anti-money laundering (AML) regulations obligating most jewelry manufacturers and non-exempt jewelry retailers to develop AML programs has been in effect since December 31, 2005.
In a release issued on November 21, JVC said that jewelers who have not yet complied, risk fines and other penalties. The committee offered jewelers JVC’s specialized services and products to help them create and test AML programs.
The new regulations were finalized by the Financial Crimes Enforcement Network (FinCEN) in June 2005. Under the law, it is mandatory for jewelers to have their AML programs tested once a year. A company’s compliance officer cannot test its own program.
Testing includes reviewing the AML program, customer and supplier identification program, transaction monitoring and more. JVC’s testing prepares a business for an IRS visit. The IRS can come to review the AML program, examine transactions, or they can review a company’s general books and records such as cash receipts, journals and bank statements.
The JVC PACK contains instructions, templates and a CD with forms to develop an AML program and a door sticker to let customers and vendors know that a company is complying with the AML requirements of the USA PATRIOT Act.
Cecilia Gardner, JVC’s president, CEO, general counsel and Certified Anti-Money Laundering Specialist (CAMS) can test jewelry industry AML programs and issue a results letter on a company’s AML program implementation.
“JVC’s independent testing service is far less costly than outside counsel or an accounting firm,” said Gardner. “As the legal compliance expert in the jewelry industry, JVC has the AML knowledge and experience manufacturers and retailers can rely on to test their AML programs.”
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