Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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6/9/2005 FinCEN Issues Interim Final AML Program Rules for Dealers in Jewels, Precious Metals or Stones

FinCEN has issued interim final rules requiring dealers in precious metals, stones, or jewels to implement anti-money laundering programs. A number of significant changes were made to the rules proposed in 2003.  Dealers, to be covered, must now cross both a purchase and sale threshold of $50,000 so that, for instance, mining companies that only sell covered items generally would not have to implement AML programs. Despite describing a number of red flags in both the preamble and the text of the rule, no suspicious activity reporting requirement is imposed at this time.  Comments are sought on several issues.  The rules will be the subject of extensive analysis in the July issue of the Monitor.

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