The long relationship among precious metals, money and crime has a new partner - government regulation as a financial institution. The U.S. Congress and Treasury have dictated that "dealers in precious metals" must create and implement internal programs to detect and deter money laundering and terrorist finance. The final details are not yet fixed, but they soon will be. And even then, the final details will depend upon the vulnerability of each "dealer in precious metals" to be abused. Some precious metals businesses, particularly those dealing in lower value materials, will be excluded by the regulation itself. These businesses may elect to formalize their current business practices to protect against the same vulnerabilities, but they are not required to do so. Others will have to undertake an assessment of their business practices, and fashion an AML program that will achieve compliance.
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