Anti-Money Laundering Compliance
Gettysburg Precious Metals, LLC (“Gettysburg”) takes the utmost care to follow the law as well as maintain the highest standards of security, and is committed to reviewing the AML strategies and objectives on an ongoing basis and to maintaining an effective AML program.
We actively monitor current laws and regulations, ensuring that we remain compliant through any policy changes. Gettysburg is dedicated to following industry best practices, and shall cooperate with and take guidance from the Financial Crimes Enforcement Network, United States Department of Treasury; the Internal Revenue Service; and other appropriate regulatory and enforcement agencies.
USA PATRIOT Act Compliance
Gettysburg adheres to the USA PATRIOT Act and is dedicated to both stopping and preventing money laundering activities from taking place.
We are required to file a Form 8300 with the IRS for all cash transactions above $10,000. That form requires the customer’s Social Security Number, Date of Birth and Driver’s License information.
What Is Money Laundering?
Money laundering is defined as the attempted concealment of illegally obtained financial assets within legitimate financial systems and institutions.
There are three main steps to money laundering:
Placement occurs when the cash is placed into the financial system, such as when a money order is purchased using the illegal funds.
Layering is the transfer or transformation of the illegal funds through several forms in an attempt to confuse any efforts to trace them.
Integration is when the money is changed into a seemingly legitimate form (i.e., purchasing automobiles, businesses, real estate, etc.) that can later be sold.
Employee Training
The Gettysburg team undergoes compliance training to detect, fight, and prevent money laundering and similar crimes. This training fulfills the ongoing programming requirement outlined by the USA PATRIOT Act.
Internal Operating Procedures and Compliance Officer
The USA PATRIOT Act requires that businesses accepting cash as payment have clearly outlined standard operating procedures for employees to follow when handling financial transactions in order to detect and stop money laundering activities. These operating procedures are to be managed by an internal Compliance Officer.
Some steps that employees in such companies are expected to take in order to prevent money laundering include:
- Obtain and document official identification from all customers performing transactions;
- Use an IRS Form 8300 to report cash transactions above $10,000;
- Consult with government authorities and agencies whenever possibly suspicious activity arises.
In addition to maintaining the policies outlined in the USA PATRIOT Act, the Compliance Officer must also make sure that all federal and state anti-money laundering laws are enforced.
We note that this section’s requirements apply to businesses that accept cash for payment, which Gettysburg does not.
Annual Independent Audit
Each year, Gettysburg conducts an independent audit of the anti-money laundering processes it has in place. In order for it to be independent, the Compliance Officer cannot perform this audit.
Instead, another individual—whether senior management, an attorney, or a financial professional—who is familiar with anti-money laundering requirements and regulations should review the processes in place to ensure they are adequate, current, and properly implemented, and that all employees are trained to follow these processes.