Imperial Jewel's Anti-Money Laundering Policy

Recent Federal anti-money laundering legislation has caused Imperial Jewels to review and revise our policy for handling funds. The changes are necessary to ensure we comply with Federal money laundering regulations and not unwittingly accept payments that may aid illicit money laundering activities.

On February, 2003, the US Treasury Department published regulations that will require every "dealer in precious metals, gemstones or jewels" to develop and implement an anti-money laundering program.

These regulations require that Imperial Jewels conducts a self analysis of business practices to determine the level of risk of exploitation for criminal purposes, have clear anti-money laundering program which includes employee training, and auditing of the program on a periodic basis. We also will report suspicious activity to the appropriate Federal authorities.

Acceptable forms of payment for Imperial Jewels:

1. PayPal.
2. Personal or business checks drawn on a U.S. bank, or branch of a foreign bank located in the United States, and subject to the Bank Secrecy Act.
3. Third party checks where there is a clear connection of the third party to the underlying transaction.
4. Wires that are received and processed through banks located in the United States, and subject to the Bank Secrecy Act.

Unacceptable forms of payment for Imperial Jewels:

1. Cash.
2.Personal or business checks drawn on a non-U.S. foreign bank.
3.Third party checks where there is no clear connection of the third party to the underlying transaction.
4.Checks made payable to individual producers, insurance agencies, or to "cash".
5.Routine payments by cashier’s checks, money orders, bank drafts and traveler’s checks for $10,000 or less. Payments using these instruments will be evaluated.
6.Agents’ personal checks or checks drawn on agency bank accounts to pay for clients’ transactions.
7.Payments of any kind originating jurisdictions that have been from identified by the Department of State as a sponsor of international terrorism under 22 U.S.C. 2371

Substantial Payments And “Structuring”

In compliance with Section 103.140(c) of the U.S. Patriot Act, Imperial Jewels vets and reports to the appropriate Federal authorities all payments of over $10,000. Furthermore, clients who spend more than $10,000 within the space of one year will also be reported under the BSA Form 8300 to aid Federal authorities with possibility of payments being made in a “structuring” type method.

SDN Searches

All customer payments will have the payees name searched against the Office Of Foreign Assets Control database the Specially Designated Nationals List. Any positive identification will be immediately reported to the appropriate authorities.

Training & Management

All financial and accounting managers and staff are fully trained regarding Patriot Act and Anti-Money Laundering compliance and are retrained every six months.

Imperial Jewel’s Compliance Officer for this policy is Mr I D Turner. For any further information regarding our Patriot Act and Anti-Money Laundering compliance policies, please contact us at support@imperialjewels.com.