Anti Money Laundering (AML)

To All Customers,

You are being requested to provide information and documents to Jewelers Refining Group Inc. Please let us explain.

The U.S. Congress has classified all dealers in precious metals as financial institutions since 1970. (If you would like to have a lawyer check this, the source is the Bank Secrecy Act, 31 U.S.C. Section 5312(a) (2)). In 2001, Congress required every financial institution to have an anti-money laundering program (USA PATRIOT Act, section 352, 31 U.S.C. section 531 (g). In 2005, the United States Treasury implemented this Congressional requirement through a regulation, 31 CFR 103.140, effective as of January 1, 2006. Jewelers Refining Group is compliant with this legal requirement. Because you may also be a dealer in precious metals, subject to the same federal law, we are asking that, you certify either that you are in compliance, or are not subject to this requirement.

The essence of an AML Program is that we must know our customers – who you are and what you do. Knowing whom you are means ensuring that we have your legal name and that we are reasonably sure that you are the person that you say you are. If you are an organization, we need to have the names of the owners. We will then check your names against government lists of criminals, terrorist financiers, and persons who have been blocked from doing business with United States businesses. It is unlikely that you will appear on those lists, but we do need to check.

Knowing what you do means having an understanding that you have a legitimate reason to buy our products, or have a legitimate source for materials that you sell to us. Therefore, for example, if you are a manufacturer of gold jewelry, we understand that you may have a legitimate need to buy gold, and have a legitimate source of scrap gold for refining. We are not likely to follow that line of inquiry further. If, on the other hand, you are, say, a postal clerk, or own a grocery store, we may question why you claim to have a large amount of gold for sale. (Moreover, yes, we receive proposals like that, not frequently).

We assure you that we will not use this information and documents for any other purpose, and will not be seen by any person without AML responsibilities. We maintain these documents in locked cabinets in a facility with 24-hour security. If the government requires that we open our records, we will do so. Nevertheless, your records will not be open to any other persons. In no circumstances will we sell or give away your AML information to others.

Please feel free to contact me if you have questions or concerns.