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Specialty Metals AML Compliance Program Information
Specialty Metals is required by law, by corporate policy, and by good business practice to identify and know our customers, and to ensure that our transactions with them meet high standards of integrity. Accordingly, we require customers to provide the following information and certification, as a condition to doing business.
Read This: An Explanation of Our Anti-money Laundering Program
You are being requested to provide information and documents to Specialty Metals and you may question why. Please let me explain.
All dealers in precious metals have been classified as financial institutions by the U.S. Congress since 1970. (If you would like to have your lawyer check this, the source is the Bank Secrecy Act, 31 U.S.C. section 5312(a)(2)). In 2001, following the terrorist attacks, Congress required every financial institution to have an anti-money laundering program (USA PATRIOT Act, section 352, 31 U.S.C. section 5318(g)). Specialty Metals Smelters & Refiners, LLC complies with this Congressional requirement.
The essence of an Anti-money Laundering Program is that we must know our customers – who you are and what you do. Knowing who you are means ensuring that we have your legal name, and that we are reasonably sure that you are the person you say you are. If you are an organization, we need to have the names of the persons who control the organization, such as its officers and directors. We will then check your names against government lists of criminals, terrorist financiers, and persons who have been blocked from doing business with United States businesses. Yes, it is unlikely that you will appear on those lists. We still need to check.
Knowing what you do means having an understanding that you have a legitimate reason to buy our products, or have a legitimate source for materials that you sell to us. So, for example, if you are a manufacturer of gold jewelry, we understand that you have a legitimate need to buy gold, and also have a legitimate source of scrap gold for refining. We are not likely to follow that line of inquiry further. If, on the other hand, you are, say, a postal clerk, or own a grocery store, we may question why you claim to have a large amount of gold for sale (and yes, we receive proposals like that, not infrequently.)
We assure you that we will not use your information and documents for any other purpose, and they will not be seen by any person without Anti-money Laundering responsibilities. We maintain these documents in locked cabinets in locked rooms in a facility with 24-hour security. If the government requires that we open our records, we will do so. But your records will not be open to any other persons. In no circumstances will we sell or give away your Anti-money Laundering information to others. All information submitted through this site is sent securely.
Please feel free to contact me if you have questions or concerns.
Compliance Officer, Specialty Metals Smelters & Refiners, LLC
Anti-Money Laundering Campaign (AMLC)
New Customer Information Form
All new customers must complete our secure online AMLC form.
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Please select one of the following Anti-Money Laundering Forms: