A written BSA/AML program
Policies, procedures, and internal controls based on a risk assessment of your business, approved by senior management and available to FinCEN on request.
1027.210(b)(1)
BSA/AML · OFAC · Metals, stones, and jewels
Compliance built for the metals and jewelry trades, not borrowed from a bank.
RegSmart builds BSA/AML and OFAC sanctions programs for dealers in precious metals, stones, and jewels, including bullion dealers and jewelers, under 31 CFR Part 1027. We use AI and our own OFAC software, built for dealers, to lower the cost and raise the accuracy of compliance, and we set the program up so your own team can run it.
Required by law31 CFR 1027.210
Every dealer must have these four things.
If your business meets the dealer definition, federal law requires an anti-money laundering program with four parts. None of them are optional, and none depend on whether you take cash.
A BSA compliance officer
A designated person with the knowledge and authority to run the program day to day and keep it current.
1027.210(b)(2)BSA training
Ongoing training for every employee whose role touches customers, transactions, or metal, on their responsibilities under the program.
1027.210(b)(3)Independent testing
A test of the program by someone other than the people who run it. The rule does not set a frequency; we recommend testing annually.
1027.210(b)(4)OFAC31 CFR ch. V
OFAC compliance is not optional, for any dealer.
Sanctions rules apply to every U.S. person and business, with no size exemption and no dollar threshold. Liability is strict: selling metal or stones to a blocked person, buying from one, or releasing their stored metal is a violation even if you did not know. A dealer too small to need a BSA program still needs to screen.
The good news is that sanctions compliance is well suited to technology. RegSmart's proprietary OFAC software, designed for precious metals and jewelry dealers, screens your customers, works every alert through a defined disposition process, tracks reporting deadlines, and keeps the record. With it, a small team can run a fully compliant sanctions program in-house.
The problem31 CFR 1027.210
Most dealer programs are written for someone else.
A typical dealer AML program starts life as a bank or broker-dealer template. It promises a Customer Identification Program, beneficial ownership certifications, mandatory suspicious activity reporting, and politically exposed person screening. None of those rules are written for dealers. A written program that commits you to procedures nobody performs is a liability: auditors and examiners test what you wrote against what you do.
Meanwhile, the obligations that do apply to dealers often get thin treatment: a risk assessment that reflects your actual products and suppliers, Form 8300 cash reporting, sanctions screening of existing customers when the lists change, and a defensible way to clear or escalate a possible OFAC match.
Our approach: apply the minimum necessary force. If a requirement applies to you, we build it so your staff can follow it. If it does not, we leave it out and write down the regulatory basis so the next auditor sees a decision, not a gap.
What we build
A complete program, sized to a dealer.
Applicability review
Apply the $50,000 dealer test, the retailer exception, and the covered-goods definitions to your business, then map exactly which BSA rules reach you.
1027.100Written BSA/AML compliance program
Policies, procedures, and internal controls built on your risk assessment, with a compliance officer, training, and independent testing, approved by senior management.
1027.210OFAC sanctions program
Screening at onboarding and on list updates, a tiered alert-disposition workflow, blocking and reporting procedures, and 10-year recordkeeping.
31 CFR 501Form 8300 procedures
Cash and cash-equivalent aggregation rules, the 15-day filing clock, customer notice by January 31, and e-filing.
1010.330Training
A structured curriculum that takes a new compliance officer from zero to independent, plus annual staff training built on real dealer enforcement cases.
1027.210(b)(3)Independent testing
A test of your program against your actual practice, with findings written so management can act on them.
1027.210(b)(4)How it runs
Four stages, in this order.
Scope
Confirm dealer status, the covered goods you handle, and which rules apply. Identify what your current program says that you do not do.
Assess
Rate risk across your products, customers, suppliers, distribution channels, and geography, including the purchase side of the business.
Write
Deliver the program, operating procedures, and an addendum that documents the basis for every excluded provision.
Operate
Train the compliance officer and staff, hand over the alert workflow and templates, and set the independent testing cycle.
Recent changes
Two developments every dealer should know.
31 CFR 501.601
OFAC records: 10 years, not 5
Effective March 21, 2025, OFAC extended its recordkeeping requirement from five years to ten, matching the longer statute of limitations for sanctions violations. Retention schedules written before 2025 are likely out of date.
FinCEN NPRM, April 2026
AML program rules are being rewritten
FinCEN's April 2026 proposal to reform AML/CFT program requirements expressly covers dealers in precious metals, stones, or jewels. As of October 2026 it is a proposal, not a final rule. A well-documented, risk-based program is the best preparation.
Find out what your program commits you to.
Send us your current AML program. We will tell you what applies, what does not, and what is missing.