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FMR GOLD AML Policy and Procedures
Anti-Money Laundering & Anti-Terrorist Compliance Program
FinCEN Rule(s): 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 comprises the following four elements:
● Policies, procedures, and internal controls, based on the dealer’s assessment of the
money laundering and terrorist financing risk associated with its business.
● A compliance officer who is responsible for ensuring that the program is implemented
● Ongoing training of appropriate persons concerning their responsibilities under the
● An 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 characteristics of
jewels, precious metals and precious stones that make them valuable also make them
potentially vulnerable to those seeking to launder money,” said William J. Fox, Director of
FinCEN. “This regulation is a key step in ensuring that the Bank Secrecy Act is applied
appropriately to these businesses.”
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.”
Money laundering refers to act(s) of disguising, concealing, camouflaging, hiding, or structuring
illegal proceeds for the purpose of misrepresenting the true source of said funds. Included in
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the act of money laundering is terrorist financing, which is the act of concealment of liquid asset
or monies (both legal and illegal) in aim of supporting and/or funding acts of terrorism.
FMR GOLD, its team members, contractors and related subsidiaries apply all commercially
reasonable efforts to comply with every FinCEN regulation. As an ecommerce retailer of gold,
silver, and other precious metals, FMR GOLD, uses all commercially reasonable efforts to
source 100% of our metals from dealers that comply with all FinCEN regulations, the Patriot
Act, Office of Foreign Assets Control (OFAC) and the Bank Secrecy Act.
FMR GOLD has an expressed policy against aiding and abetting the act of money laundering,
terrorism financing or facilitating any and all illegal acts as governed by the Patriot Act, OFAC,
FinCEN as well as forbidding the violation of any U.S. state and/or federal law.
By agreeing to the posted FMR GOLD terms and conditions, and consummating a transaction
with FMR GOLD, each customer represents and warrants to FMR GOLD that (i) the customer
is in compliance with the USA Patriot Act, (ii) 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 and (iii) 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. FMR GOLD at its sole discretion 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.
Our Designated AML Compliance Officers
This compliance plan has been created and is implemented by FMR GOLD.
Stephen Paine will act as lead designated AML compliance officer responsible for setting and
enforcing FMR GOLD official AML policy. Stephen Paine is responsible for training each team
member to detect, prevent and report suspicious activity. FMR GOLD and the company
Compliance Officer can be contacted concerning AML inquiries at 1-800-895-8603 during
normal business hours or by emailing Stephen@FMRGold.com.
The AML compliance officer will also ensure that FMR GOLD maintains all required AML
records and will ensure that Suspicious Activity Reports (SARs) are filed with the Financial
Crimes Enforcement Network (FinCEN) when appropriate. The AML compliance officer is
vested with full responsibility and authority to enforce the FMR GOLD AML program.
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Independent Review of our Anti-Money Laundering Plan
Every 12 months, the FMR GOLD outside licensed accountant or another qualified individual
will audit the FMR GOLD AML plan of action to ensure company AML strategies, policies and
due diligence procedures are being implemented as designed and adequate to stop any
attempts to infiltrate the company business. These reviews and transaction audits will always
be completed by someone not involved in the plan’s creation.
FMR GOLD AML RISK ASSESSMENT
1 – Country/Geographic Risks
We have no Country/Geographic risks based on the definition of Country/Geographic Risks
used by FINCEN, FINRA or any other U.S. authority that oversees money laundering activities.
FMR GOLD does not ship outside of the US. Our main business activity is selling precious
metals (Minted Gold and Silver bars and coins) to U.S. collectors and investors that want to
maintain a diversified precious metals portfolio.
FMR GOLD sells to customers that want to buy for physical possession and the metals are
shipped directly to the customer. All funds come via U.S. bank personal check, US bank
cashier’s check, U.S. bank wire transfer, or credit card.
FMR GOLD reviews all new customers and orders for risk. When deemed necessary by the
compliance department, FMR GOLD conducts phone interviews by trained sales
representative to further assess the risk a prospective customer might pose.
As a further security measure, all calls may be monitored and recorded for compliance and
FMR GOLD does not accept cash as payments for any precious metal transaction.
2– Product Risk
FMR GOLD offers bullion gold, silver, platinum and palladium bars and coins. In addition to
bullion, FMR GOLD offers customers premium numismatics and semi numismatics which
carry a higher premium than their bullion counterpart. Such products are less desirable to
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money launderers as the cost is much higher than the metals melt value and are more difficult
to convert to immediate cash.
3– Financing Method
FMR GOLD accepts credit cards, U.S. bank personal checks, U.S. bank cashier’s checks, and
U.S. bank wire transfers only. We do not accept foreign checks, wires, or cash for payment of
any precious metal product.
4- Proof of Citizenship
If FMR GOLD has reason to suspect a prospective customer is attempting to hide his or her
motive for purchasing any offered precious metals product. FMR GOLD policy is to request
for review the following additional information:
1. Valid U.S. ID or Passport.
2. Valid Credit Card with customer name.
3. Shipping Address matching U.S. ID
4. Bank Name and account number
If the prospect customer declines to provide the required information, FMR GOLD will decline
the transaction and report it to the AML compliance officer.
FMR GOLD will use best efforts to document our verification: including all identifying
information provided by a customer, the methods used and results of verification, and the
resolution of any discrepancies identified in the verification process. FMR GOLD will use best
efforts to retain records containing a description of any document that we relied on to verify
a customer’s identity, noting the type of document, any identification number contained in
the document, the place of issuance, and if any, the date of issuance and expiration date.
5- Monitoring Accounts for Suspicious Activity
FMR GOLD monitors account activity for unusual size, volume, pattern, or type of transaction,
considering risk factors and red flags that are appropriate to our business. The AML
compliance officer or his designee will be responsible for monitoring and reviewing all
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customer account activity. FMR GOLD will determine whether any additional steps are
required and will report suspicious activities to the appropriate authorities.
6- Emergency Notification to Law Enforcement by Telephone
In situations involving violations that require immediate attention, such as terrorist financing
or ongoing money laundering schemes, we will immediately call an appropriate law
Further information regarding the money laundering prevention (AML) practices of FMR
GOLD may be requested by email Stephen@FMRGold.com or by calling (800)- 895-8603,
Monday-Friday 9am- 5pm CST
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