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Anti-Money Laundering Consulting

Do you have (or need) an anti-money laundering program in place? (IRS/FinCen-2005)
  • Do you do $50,000 in and out in non-pawn covered goods in a year?
  • Do you know what covered goods are?
  • Do you have a compliance officer? Training program? Independent Annual audits?
  • Fines average $25,000 and can go much higher
Need help with AML

Other Services

  • INDEPENDENT AML REVIEWS-MSB’S
  • INDEPENDENT AML REVIEWS-PRECIOUS METALS DEALERS
  • AML TRAINING OF STAFF AND MANAGEMENT
  • FIREARMS PROGRAM MANUALS
  • INDEPENDENT FIREARM AUDIT
  • EMPLOYEE HANDBOOKS
  • SAFETY MANUALS AND INSPECTIONS
  • MLA GUIDANCE
  • CORPORATE MINUTE PREPARATION
  • SAFETY AND SECURITY AUDITS
  • GENERAL BUSINESS CONSULTING
  • PAWN SOFTWARE GUIDANCE
  • START-UPS GUIDANCE
  • QUICKBOOKS SETUP AND TRAINING BOOKKEEPING
  • SERVICES QUARTERLY ANALYSIS AND REVIEW
  • BEST PRACTICES GUIDANCE
  • SUCCESSION PLAN GUIDANCE
  • MUNICIPAL CODE ASSISTANCE

Primary Federal Statutes and Regulations Applicable to the Pawn Industry

1. Internal Revenue Service Form 8300 – cash transaction reporting by persons engaged in trades or business.
2. Bank Secrecy Act – “suspicious activity reporting” – currently voluntary for the pawn industry.

3. U.S. Office of Foreign Asset Controls’ “Specially Designated Nationals” Regulations – US persons prohibited from doing business with persons and organizations on the list. Source: Treasury Department, Office of Foreign Assets Control regulations; various statutes and Executive Orders dating back to 1812.
4. USA PATRIOT Act – designated pawnbrokers as “financial institutions” subject to the Bank Secrecy Act for some purposes; pawn industry anti-money-laundering regulation pending.
5. U.S. Financial Crimes Enforcement Network’s “Precious Metals Dealers” Rule – implements Bank Secrecy Act anti-money-laundering compliance obligations of dealers in precious metals, precious gems or stones or jewelry containing any or all who meet specified thresholds of activity in a given year, except when selling property previously held as collateral for pawn transactions.
6. Truth in Lending Act – disclosure of credit terms in consumer credit transactions.
7. Gramm-Leach-Bliley Financial Services Modernization Act of 1999 (GLBA) – pawnbrokers designated as “financial institutions;” Title V gives rise to financial privacy rights for consumers and requires providers such as pawnbrokers to protect the privacy of “non-public personally identifiable information” obtained from consumers, subject to limited exceptions allowing disclosures.
8. FTC/CFPB Privacy Rule – explains and implements provisions of GLBA privacy rights.
9. FTC/CFPB Safeguards Rule – explains and implements provisions of GLBA safeguards for consumers’ nonpublic personal information.
10. Fair Credit Reporting Act – restricts sharing of nonpublic personal information with unaffiliated third parties; requires care in disposal of consumer information.
11. FTC Consumer Information Disposal Rule – implements the 2003 Fair and Accurate Credit Transactions Act amendments to the Fair Credit Reporting Act on disposal of consumer information.
12. FTC Red Flag Rule – requires development of programs and procedures to identify possible identity theft cases.
13. Equal Credit Opportunity Act – prohibits discrimination in consumer credit transactions on basis of gender, age, marital status, ethnicity, national origin, religious preference, or receipt of public assistance income.
14. Servicemembers Civil Relief Act of 2003 – limits interest rates and charges assessable on military personnel for credit transactions entered into prior to their active duty status and provides specified remedies to service members.
15. Military Lending Act – generally limits consumer credit to a Military Annual Percentage Rate of 36% for active duty service members and their dependents. Pawnbrokers were not covered by the original Department of Defense 2007 Regulations and there is no basis for extending it to the pawn industry now.

Copyright © National Pawnbrokers Association 2016. All rights reserved.

Would you like my help?
  • 20 years of experience as a licensed pawnbroker
  • 15 years on the Oregon Pawnbrokers Assn. Board of Directors
  • Currently serving on Washington State Pawnbrokers Assn. Board of Directors
  • 125+ accounts in Oregon, Washington, California, and Alaska

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  • Home
  • Services
    • Pre-Audit Worksheet
  • Reviews
  • Contact
  • Compliance Training