At Gemone Diamonds, we are committed to conducting our business with the highest ethical standards and in compliance with all applicable laws and regulations, particularly those concerning anti-money laundering (AML) and counter-terrorist financing. This policy is designed to protect our business and clients from the risks of money laundering, terrorist financing, and other illegal financial activities.
Compliance with FinCEN Regulations
In accordance with the Financial Crimes Enforcement Network (FinCEN) regulations, Gemone Diamonds, as a dealer in precious metals, stones, and jewels, has implemented a comprehensive Anti-Money Laundering Program (AML Program). This program is designed to detect and prevent the misuse of our products for illegal activities and includes the following key components:
-
Policies, Procedures, and Internal Controls
We maintain robust policies and procedures to assess and mitigate the risk of money laundering and terrorist financing. These are regularly updated to align with the evolving risks and regulatory landscape in the diamond and jewelry industry. -
Designated Compliance Officer
A dedicated compliance officer is appointed to oversee and implement our AML Program. This individual ensures that the program is effective and that all compliance obligations are met. -
Ongoing Training
We provide regular AML training to employees and relevant stakeholders. This ensures that they are aware of their responsibilities under our AML Program and can recognize suspicious activities that may indicate money laundering or terrorist financing. -
Independent Testing and Monitoring
Our AML Program undergoes independent testing to ensure its adequacy. This includes routine reviews of transactions, customer due diligence, and internal controls to maintain compliance with applicable laws and standards.
Dealer and Customer Responsibilities
As a dealer in precious stones and metals, Gemone Diamonds strictly follows the FinCEN regulation for businesses that have purchased or sold more than $50,000 worth of "covered goods" in the previous year. "Covered goods" include jewels, precious metals, and stones, as well as finished products such as jewelry or antiques that derive 50% or more of their value from these materials.
By engaging in business with Gemone Diamonds, our clients affirm that:
- Their transactions do not involve funds related to money laundering, terrorism, or other illicit activities.
- They comply with the USA Patriot Act and all applicable AML regulations.
- Their financial activities with us are legitimate and lawfully conducted.
We reserve the right to request supporting documentation to validate the source of funds and ensure compliance with all relevant regulations.
Red Flags and Suspicious Activity Reporting
All employees and agents of Gemone Diamonds are trained to identify suspicious activity that may be associated with money laundering or terrorist financing. Examples of such activities include:
- Customers providing insufficient or suspicious information.
- Unusual payment methods or volumes inconsistent with business norms.
- Payments from unrelated third parties or countries considered high-risk for money laundering.
If any red flags are identified, employees must report the suspicious activity to the compliance officer without notifying the customer or party involved. We are committed to cooperating with law enforcement and financial regulatory bodies in the event of an investigation.
Due Diligence and Record-Keeping
We conduct thorough due diligence on all customers, suppliers, and business partners to verify their identity and ensure their funds are derived from legitimate sources. This due diligence is ongoing throughout the business relationship, and all records are meticulously maintained to support future audits and investigations.
Non-Compliance Consequences
Any violation of our AML Policy may result in disciplinary action, including termination of employment or business relationships, as well as civil and criminal penalties. We regularly audit our operations to ensure full compliance with global AML laws and regulations.
Policy Review
Gemone Diamonds is committed to continuously updating our AML policies and procedures to adapt to new risks and regulatory changes. This policy is reviewed periodically to ensure it remains effective and aligned with industry best practices.
For any questions or concerns regarding this AML Policy, please contact our compliance officer.