Insight From Our Experts

AS I PERFORM ANNUAL INDEPENDENT AML REVIEWS ACROSS THE COUNTRY, I run across the same issues time and time again, the biggest of which is training not being performed either on time or at all. Title 31 of the U.S. Code, otherwise known as the USA PATRIOT Act, requires all precious metals dealers to have an AML program and they must train their staff on the following occasions:

• Within 30 days of hire

• Annually as a refresher

• Anytime the law changes

Employees who require training are those who interact with customers at the loan and sales counters, are in administration or are on the Board. Basically, if they handle cash or are in charge of those who do, then training is required. Those who do online sales or other services like warehouse work or jewelry repair are excluded from this requirement.

To pass muster, there needs to be good documentation of training. Be sure to record:

• What was discussed with some detail

• Who attended the training

• Who presented the training

• The date of the training

Attendees should sign a register or some sort of document that proves they were in attendance, along with what training they received. These documents should be retained for a minimum of five years before…