JVC Offers Additional Patriot Act Contract Services


October 28, 2005

JVC Offers Additional Patriot Act Contract Services

Jewelers Vigilance Committee is providing targeted anti-money laundering compliance contract services to owners of JVC's USA PATRIOT Act Compliance Kit and JVC members. Services are available immediately and will remain available after Jan. 1, the deadline to comply with AML regulations. Cecilia L. Gardner, JVC's president, CEO and general counsel and author of JVC's PACK, provides all AML services.

Earlier this year, FinCEN (Financial Crimes Enforcement Network) issued final rules requiring "dealers in precious metals, precious stones, jewels and covered goods" to implement an anti-money laundering program. Dealers who buy these products in an amount in excess of $50,000 in one year and receive more than $50,000 in gross proceeds from the sale of precious metals, stones and jewels during the same period, must comply by the Jan. 1 deadline.

JVC's additional programs address specific AML requirements. Contract services include:

  • Anti-Money Laundering Program and Policy Development – Companies are required to assess their level of risk; JVC will assess the risks associated with a business or company and develop the company's written AML program and AML policy.
  • Employee-Training Program Pertaining to Money Laundering – Companies are required to develop and implement employee-training based on the AML program. JVC will develop a written employee-training program and train employees to recognize and deal with money-laundering attempts within the scope of their employment. And, JVC will provide a record stating the program has been implemented.
  • Testing of Anti-Money Laundering Programs – The USA PATRIOT Act requires independent periodic testing of AML programs to monitor and maintain an adequate program. JVC will test your company's AML program to monitor and evaluate the functioning of the program and deliver a "Results Letter" on the subject.

JVC's other services include Ask the Expert, a secure, web-based service where PACK owners and JVC members can ask Cecilia Gardner pertinent questions about how to develop their AML programs or even about specific transactions that might raise concerns. "Ask the AML Expert" is completely confidential and the only AML service of its kind in the jewelry industry.

"My previous experience with FinCEN and Treasury and as a former federal AML prosecutor for 13 years insure that JVC's PACK and complementing AML support services is the definitive package to cover all compliance obligations," says Gardner. PACK is easy-to-use and understand, and can be customized for virtually every area of the jewelry industry, she says.

"JVC's contract services are ideal for those who need help designing a compliance program or meeting the other elements required under the rules – JVC is uniquely positioned to help," says Gardner. "JVC's role as the legal compliance expert, combined with our educational experience on compliance and my expertise on AML legal requirements, will serve the industry well in fulfilling their compliance obligations."

Contract services are provided for a reasonable fee, depending on the size of the company and the service provided. JVC's Web based "Ask the AML Expert" is free to owners of JVC's compliance kit. For more information on JVC's USA PATRIOT Act Compliance Kit, please visit JVC's Web site: www.jvclegal.org.

by Peggy Jo Donahue

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