Plain-English guide

AML requirements for jewelers

Updated October 2026 · Based on FinCEN's rule for dealers in precious metals, precious stones or jewels, 31 CFR Part 1027

Most jewelers know about Form 8300 for big cash sales. Fewer know that many jewelers, gold buyers and precious-metals dealers must have a written anti-money-laundering (AML) program. That requirement comes from the Bank Secrecy Act and FinCEN's dealer rule at 31 CFR Part 1027. This guide covers who the rule applies to, what the program must contain, and the related cash and recordkeeping rules.

1. Are you a covered "dealer"?

FinCEN's rule applies to "dealers" in covered goods: jewels, precious metals, precious stones, and finished goods (such as jewelry, numismatic items and antiques) that get 50% or more of their value from those materials (31 CFR 1027.100(a)).

You are generally a dealer if you are in the business of buying and selling covered goods in the US and, during the prior calendar or tax year, you both:

• bought more than $50,000 of covered goods, and
• received more than $50,000 in gross proceeds from selling covered goods (31 CFR 1027.100(b)(1)).

For finished goods like jewelry, only the value of the jewels, precious metals or precious stones counts toward those thresholds (31 CFR 1027.100(b)(5)).

Retail jewelers get a narrower test. A retailer, meaning a business that sells covered goods mainly to the public, is a dealer only if it bought more than $50,000 of covered goods from people other than dealers or other retailers during the prior year (31 CFR 1027.100(b)(2)(i), (f)). In practice that means buying from the public, such as scrap gold, estate jewelry or loose stones brought to the counter. If a retailer crosses that line, its program only has to cover those purchases (31 CFR 1027.210(a)(2)).

Some activity doesn't count. Taking a customer's piece as a trade-in and crediting it toward a purchase, without paying out funds, isn't a purchase under the rule (31 CFR 1027.100(b)(3)). Licensed pawnbrokers are excluded for their pawn transactions (31 CFR 1027.100(b)(2)(ii)). Outright jewelry and gold buying at a pawn shop may still count.

2. What the AML program must include

A covered dealer must have a written AML program, reasonably designed to keep the business from being used for money laundering or terrorist financing. The program must be approved by senior management, and you must make it available to FinCEN on request (31 CFR 1027.210(a)). At minimum, it must include four things (31 CFR 1027.210(b)):

1. Policies, procedures and internal controls based on a risk assessment. Your assessment must consider the types of products you buy and sell; the nature of your customers, suppliers and distribution channels; your geographic locations; dealings with anyone other than established customers or suppliers; and payments tied to jurisdictions flagged by the State Department, international bodies or Treasury (31 CFR 1027.210(b)(1)(i)). Your procedures must also help you spot suspicious transactions, make reasonable inquiries, and refuse or walk away from a deal when needed (31 CFR 1027.210(b)(1)(ii)).
2. A designated compliance officer. This person makes sure the program is carried out, kept up to date, and that the right people are trained (31 CFR 1027.210(b)(2)).
3. Ongoing training for the employees who need it, on their responsibilities under the program (31 CFR 1027.210(b)(3)).
4. Independent testing, with scope and frequency matched to your risk. An officer or employee can do it, but not the compliance officer or anyone involved in running the program (31 CFR 1027.210(b)(4)).

Timing: new dealers must have the program in place within six months of becoming subject to the rule (31 CFR 1027.210(c)).

3. Red flags FinCEN names

The rule lists specific warning signs your procedures should account for (31 CFR 1027.210(b)(1)(ii)). Here's what they can look like at a jewelry counter:

• Unusual payment methods, such as large amounts of cash, sequentially numbered money orders, traveler's checks or cashier's checks, or payment from a third party.
• Reluctance to give accurate contact details, financial references or business affiliations.
• Unusual secrecy, such as asking you not to keep normal records.
• Purchases or sales that don't fit the customer. A first-time seller with a bag of identical new chains is one example.
• Deals that break standard industry practice, such as a buyer indifferent to price or quality.

A red flag doesn't automatically mean a crime. It means your staff should slow down, ask reasonable questions, document what happened, and escalate to the compliance officer.

4. Cash over $10,000: Form 8300

Separate from the AML program, any trade or business that receives more than $10,000 in currency in one transaction, or in related transactions, must report it on Form 8300 (31 CFR 1027.330, which points to 31 CFR 1010.330). Related transactions include those between the same payer and recipient within 24 hours (31 CFR 1010.330(c)(12)). Cashier's checks, bank drafts, traveler's checks and money orders with a face amount of $10,000 or less count as cash in two situations. The first is a "designated reporting transaction": a retail sale of a consumer durable (an item for personal use expected to last at least a year and priced over $10,000), a collectible, or a travel or entertainment activity. The second is any transaction where you know the instrument is being used to avoid reporting (31 CFR 1010.330(c)(1)(ii), (c)(2), (c)(7)). The report is generally due within 15 days of receipt. Installment payments are added up over a year (31 CFR 1010.330(b)). Keep a copy of each Form 8300 for five years (31 CFR 1010.330(e)(3)).

5. Recordkeeping

Part 1027's recordkeeping section points to FinCEN's general recordkeeping rules (31 CFR 1027.410, referring to 31 CFR 1010.410). Records required under FinCEN's rules generally must be kept for five years (31 CFR 1010.430(d)). A practical habit is to keep your program documents, risk assessments, training logs, testing results and transaction notes together, and to keep them for at least that long.

6. Suspicious activity reports

Part 1027 doesn't currently contain a mandatory suspicious-activity-reporting section; §1027.320 is marked "Reserved." Your program still has to help you identify suspicious transactions and decide whether to proceed (31 CFR 1027.210(b)(1)(ii)). Check FinCEN's current guidance on voluntary reporting, and talk to counsel about your situation.

7. A simple starting checklist

1. Add up last year's covered-goods purchases and sales, and for retail stores, purchases from the public.
2. If you're over the thresholds, name a compliance officer.
3. Complete a written risk assessment.
4. Write policies and counter procedures that address the red flags.
5. Have senior management approve the program in writing.
6. Train the staff who buy, sell or handle payments.
7. Schedule independent testing by someone who isn't the compliance officer and isn't involved in running the program.
8. Set up Form 8300 procedures and a five-year record system.

More guides

• Do jewelers need an AML program?
• Form 8300 for jewelers: cash over $10,000
• Buying gold from the public: the $50,000 rule
• AML risk assessment for jewelry stores
• Independent testing for jewelers

Sources

• 31 CFR Part 1027: Rules for Dealers in Precious Metals, Precious Stones, or Jewels (eCFR)
• 31 CFR 1010.330: Reports relating to currency in excess of $10,000 (eCFR)
• 31 CFR 1010.430: Nature of records and retention period (eCFR)
• Financial Crimes Enforcement Network (FinCEN)
• IRS: Form 8300 and reporting cash payments of over $10,000

This guide summarizes federal rules as of the date above. State law and your own facts may add requirements. It isn't legal advice, so talk to a qualified attorney about your situation.