Guidepost was engaged by an online luxury goods reseller to develop an anti-money laundering (“AML”) compliance program for its high-end jewelry business. The program, tailored to the reseller’s business, was intended to be consistent with the expectations of the Financial Crimes Enforcement Network (“FinCEN”) while also incorporating industry best practices.
We drafted an AML compliance policy with designation of internal roles and responsibilities, the identification of red flags for mitigating money laundering and terrorist financing risks, and a process for conducting due diligence on suppliers of high-end jewelry to the reseller. Additionally, a key component of an effective AML compliance program is training. We designed, for the client, a training program that ensures the reseller’s employees can spot potentially suspicious activity and report it appropriately.