As a dealer, processor and refiner of precious metals, Mid-States Recycling and Refining adheres to the formal anti-money-laundering requirements of the USA Patriot Act.
Those regulations require that we accumulate and maintain certain information on all companies or individuals with which we do business. To simplify the process, we have provided an online Customer Account Data Sheet we require companies to submit online or print and mail or fax to our AML compliance officer at 847-298-3910.
History of the Act
After Sept. 11, 2001, the U.S. Congress enacted a series of requirements and authorizations intended to prevent the laundering of money used to finance further acts of terrorism.
Section 352 of the USA Patriot Act requires that all “financial institutions” create and implement an anti-money laundering (AML) program. Subsequent modifications to the original Bank Secrecy Act of 1970 – which defines what and who is classified as a “financial institution” – have gone on to include “dealers in precious metals, stones or jewels.”
Recognizing that a company is most familiar with its own operations, the U.S. Treasury Office of Foreign Assets and Control has allowed each required company to develop and implement its own AML program. Certain basic customer identification information is required in all AML programs. In some instances, additional background and banking information may be required.
The information we require is solely for the internal use of our company’s AML compliance officer only and is not being collected to share with any government agencies.
Who is subject to the Act?
If you or your company operates as a “dealer in precious metal, jewels or stones,” your activities fall within the definition of “financial institution” as stated above.
Certain businesses may be exempt from being required to implement their own formal AML programs, at least for the time being. This may include some retail jewelers, manufacturers or wholesalers (especially those dealing with less than $50,000 annually) as well as those dealing strictly in silver or precious metals containing less than 50% gold by weight. Regulations regarding pawnbrokers have not been finalized.
