JOHN BULLOCK

ATTORNEY


THE AML RULE FOR DEALERS IN PRECIOUS METALS

After September 11, 2001, the U.S. Congress enacted a series of requirements and authorizations intended to protect against further acts of terrorism, including Section 352 of the USA PATRIOT Act, which requires that all "financial institutions" must create and implement an anti-money laundering (AML) program. One type of "financial institution" is a "dealer in precious metals, stones or jewels." The U.S. Treasury issued a new regulation, the AML Rule, to implement this requirement, published in the Federal Register on June 9, 2005. Businesses that buy and sell precious metals need to quickly determine if they will be covered by this requirement, and what they will need to do to comply. The papers contained here, "AML for Precious Metals - Beyond the Final Rule", presented at the 2005 Annual Conference of the International Precious Metals Institute, and ""Practical Lessons in AML Implementation", presented at the 2005 Annual Conference of the IPMI, describe the rule, its applicability, and its requirements.


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