If I am a retailer and buy from members of the public who are not “dealers” (as defined in the PATRIOT Act rules) must I comply with AML regulations?
A. If you buy precious metal, precious stones, jewels or finished goods from members of the public or anyone not otherwise covered by these rules (such as foreign sources of supply) in an amount in excess of $50,000 in 2007 you must implement an AML Program and Policy. As a retailer, your AML program would address those purchases.
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