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AML program for jewelers and dealers in precious metals, stones and jewels
FinCEN requires dealers that buy and sell more than $50,000 of covered goods a year to run a written, risk-based AML program. Most retail jewellers are exempt from the program, but not from Form 8300 cash reporting.
- A business is a "dealer" under 31 CFR 1027.100 if, in the prior calendar or tax year, it bought more than $50,000 and sold more than $50,000 of covered goods.
- Retailers selling mainly to the public are exempt unless they bought more than $50,000 of covered goods from people other than dealers or retailers, such as the public or foreign suppliers.
- A covered dealer needs a written program approved by senior management, with a risk assessment, a compliance officer, ongoing training and independent testing.
- Dealers have no mandatory SAR duty, but every trade or business must file Form 8300 within 15 days of receiving more than $10,000 in cash.
What it is
The Bank Secrecy Act treats dealers in precious metals, precious stones or jewels as financial institutions. FinCEN's program rule, now at 31 CFR Part 1027, requires covered dealers to "develop and implement a written anti-money laundering program reasonably designed to prevent the dealer from being used to facilitate money laundering and the financing of terrorist activities through the purchase and sale of covered goods" (section 1027.210).
Covered goods are jewels (such as pearl), precious metals (gold, silver, platinum and five other metals at 500 parts per thousand purity or more), precious stones (diamond, ruby, sapphire, emerald and others listed), and finished goods such as jewellery, coins and antiques that take 50 per cent or more of their value from those materials.
The rule has applied since 1 January 2006. FinCEN's 2005 FAQs say the IRS examines dealers. FinCEN's April 2026 proposal would rewrite section 1027.210 along with ten other program rules. It is not yet final.
Who it applies to
Coverage turns on a two-part test applied to the prior calendar or tax year, and it is re-run every year. You are a dealer if you are in business in the US buying and selling covered goods and you:
- bought more than $50,000 of covered goods, and
- received more than $50,000 in gross proceeds from selling covered goods.
- For finished goods, only the value of the metals, stones or jewels they contain counts toward the $50,000.
- Licensed pawnbrokers are excluded for their pawn transactions.
A retailer, meaning a business selling covered goods primarily to the public, is exempt unless it bought more than $50,000 of covered goods from people other than dealers or retailers. If it crosses that line, its program only needs to address those purchases, not its sales. A new dealer has six months to put a program in place. Form 8300 binds every trade or business, including exempt retailers.
What you have to do
Section 1027.210 sets four minimum elements. FinCEN leaves the detail to each dealer, scaled to its own risk.
- Assess your risk and write the program
Base policies, procedures and controls on a risk assessment of your products, customers, suppliers, channels and locations. Senior management approves the written program, and FinCEN can ask to see it.
- Make reasonable inquiries on unusual transactions
The rule lists red flags such as large cash or sequential money orders, third-party payments, incomplete contact details and unusual secrecy. Your program must let you ask questions and refuse or walk away from a deal.
- Check high-risk jurisdictions and parties
The risk assessment must consider payments routed through state sponsors of terrorism, jurisdictions designated non-cooperative, or jurisdictions under section 311 special measures.
- Appoint a compliance officer and train staff
Designate a compliance officer responsible for running the program, keeping it current and making sure appropriate staff are trained. FinCEN's FAQs say the role need not be full time.
Governance - Test the program independently
Scope and frequency follow your risk assessment. An employee can do it, provided they are not the compliance officer or involved in running the program.
Periodic - File Form 8300 for cash over $10,000
File within 15 days of receiving more than $10,000 in cash in one or related transactions, give the payer a written statement by 31 January the following year, and keep copies for five years.
Filed with IRS and FinCEN
What firms get wrong
Most confusion sits with the retailer exemption and Form 8300.
A retailer that bought more than $50,000 of covered goods from the public or foreign suppliers in the prior year, and also sold more than $50,000, is a dealer. Its program covers those purchases.
FinCEN's FAQs say excluded businesses are not relieved of Form 8300. For retail sales of collectibles such as gems and metal, the IRS treats cashier's checks, bank drafts, traveller's checks and money orders of $10,000 or less as cash.
Section 1027.320 is reserved, so there is no mandatory SAR duty. FinCEN strongly encourages voluntary SARs. Voluntary filers have safe harbour and must not tip off the people involved.
What happens when
- In force
Dealers must have AML programs in place (or within six months of becoming a dealer) Source
- In force
Rules move to 31 CFR Part 1027 in FinCEN's chapter X reorganisation (75 FR 65812) Source
- In force
Form 8300 must be e-filed by businesses that file 10 or more other information returns Source
- Proposed
FinCEN proposes AML/CFT program reform, including a revised section 1027.210 Source
- Proposed
Comments close on the program reform proposal Source
- Not yet setProposed
Final program reform rule Source
Not yet confirmed. We will update this when the date is set.
Related guides
Questions people ask
Does my jewellery store need an AML program?
Only if, in the prior year, you bought more than $50,000 of covered goods from people other than dealers or retailers (for example the public or foreign suppliers) and sold more than $50,000. If so, the program needs to cover those purchases.
How do I count the $50,000 for jewellery?
Count only the metal, stone or jewel content of pieces that take 50 per cent or more of their value from it. Trade-ins credited to a customer's account, with no money paid out, do not count.
When do I file Form 8300?
Within 15 days of receiving more than $10,000 in cash in one transaction or related transactions. You may also file voluntarily for a suspicious transaction of $10,000 or less.
Do dealers have to file suspicious activity reports?
No. The rule does not require SARs. FinCEN strongly encourages voluntary filing. On the FinCEN SAR, dealers select "Other" and enter "DEALER IN PRECIOUS METALS STONES JEWELS".
Is the rule changing?
FinCEN proposed a revised dealer program rule in April 2026. As at 5 November 2026 it is still a proposal.
Primary sources
Checked 5 Nov 2026. We review this page every 90 days and when the rules change.
- eCFR, 31 CFR Part 1027: Rules for Dealers in Precious Metals, Precious Stones, or Jewels
- FinCEN, Frequently Asked Questions: Interim Final Rule, Anti-Money Laundering Programs for Dealers in Precious Metals, Stones, or Jewels (2005)
- IRS, IRS Form 8300 reference guide (updated 27 Jul 2026)
- FinCEN, FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs (7 Apr 2026)
- Federal Register, Anti-Money Laundering and Countering the Financing of Terrorism Programs, proposed rule (10 Apr 2026)
- FinCEN, FinCEN SAR Electronic Filing Instructions
Where StackGo fits
StackGo is compliance middleware. For a US dealer, IdentityCheck can support the customer and supplier checks your program calls for. It does not write the program or file reports.
- Onboarding forms for customers and suppliers, and risk assessment forms with scoring and enhanced due diligence steps.
- Biometric identity verification: a photo of a government ID document plus a live selfie with liveness, covering 12,500 document types from 230+ countries and territories.
- PEP, sanctions and adverse media screening, with ongoing monitoring of screened parties.
- It does not file Form 8300, SARs or any other report.
- No transaction monitoring or cash tracking across related transactions.
- No legal advice on whether your business is a dealer.
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