I may be wrong on this, but it is my understanding that most small
retailers are not going to need to do anything on the Patriot Act
issue, other than make sure that their major suppliers are in
conformance (which you'll know because they all make you sign a bunch
of paperwork relating to it now). When this first came up as an
issue, I read the law fairly closely and it seems that most retailers
don't need to do much. This is from the JVC web site:
" Retailers who purchase their covered goods from US based dealers
already covered by the rule and from other retailers will not be
required to establish anti-money laundering programs."
So as long as you are purchasing from US based gem and metals
dealers (assuming they are in compliance) you don't have to do a
thing. If in fact you are purchasing $50,000 or more directly from
foreign dealers (or the public) then you have to have a plan in
house. Also from the JVC:
Definition of the term "dealer:" A person who both purchases at
least $50,000 worth of covered goods and sells at least $50,000 worth
of covered goods during the preceding year.
So it is not the fact that you have purchased $15k and sold $45k
that puts you over the threshold, but only if you both purchase $50k
in covered goods (which again means goods from foreign uncovered
dealers) and have sold $50k of the same goods in the previous year. I
would say if the numbers you are giving us are real then you have
absolutely no obligation to do anything about the act. But........I'm
not a lawyer, so don't do anything based on what I'm telling you. JVC
does have a fair amount of on their website about it and
you can always call them and check with them if you are in doubt.
On a personal note, it is my belief that this act has absolutely
nothing to do with terrorism but is merely an attempt by the
government, under the guise of terrorism, to completely quash the
cash marketplace out there. I find this quite amusing now given that
no one's credit cards/personal data seem to be safe from theft
anymore. So basically the government is forcing people to be the
subject of credit card/identity fraud by eliminating any other means
to conduct business. But then that's just my opinion. I'm sure there
Daniel R. Spirer, G.G.
Daniel R. Spirer Jewelers, LLC
1780 Massachusetts Ave.
Cambridge, MA 02140