Division One Compliance, LLC

Specialized BSA AML/CFT Compliance Solutions for Precious Metals Dealers

Cost-effective, easily implementable compliance tools designed to fully address BSA AML/CFT regulatory requirements governing precious metals dealers, wholesalers, and bullion traders.

Request Precious Metals Services

Tailored Compliance Built for Precious Metals Dealers

Precious Metals Architecture & Precision Tools

Dealers in precious metals face strict federal regulation under Bank Secrecy Act (BSA) rules (31 CFR 1027.210). Under FinCEN regulations, dealers buying and selling covered goods (exceeding statutory thresholds) must maintain a written, risk-based AML/CFT program.

Major banks and supply chain wholesalers regularly demand proof of a fully functioning AML/CFT compliance program and a formal risk assessment process before extending banking services or wholesale credit lines.

Division One Compliance (D1C) delivers compliance products designed specifically for precious metals dealers, wholesalers, and bullion traders. Refined and proven in the industry since 2012, our precision tools establish the exact risk-based framework banking partners and federal regulators demand without creating unnecessary administrative burden for your business.

Our Precious Metals Product Suite

ML/TF Risk Assessment & Risk Assessment Process

A risk assessment is the foundation of a compliance program. D1C evaluates your specific operational model—including wholesale sourcing, retail sales, cash transactions, bullion trading, customer types, and geographic footprint—to produce a risk assessment that will meaningfully guide your compliance efforts.

AML/CFT Policy Manual (Compliance Program)

Concise and meaningful compliance policies, procedures, and internal controls designed to guide your daily operations and satisfy bank and regulatory reviewers. Our written programs replace overwhelming regulatory jargon with clear, implementable operational guidelines.

Precious Metals Industry Specific AML/CFT Training

Generic AML training fails to address precious metals industry concerns (such as large cash payments, red-flag customer behavior, and trade-based money laundering risks). D1C provides online training designed explicitly for precious metals dealers and their personnel. Staff can complete our targeted modules online in about 15 minutes.

👉 Access the Precious Metals Online AML Training Course

Anticipating FinCEN April 2026 Proposed Regulations

FinCEN's proposed regulatory updates emphasize the need for a risk-based AML/CFT program. D1C’s compliance suite directly incorporates the key elements for creating a risk-based program. These elements include:

Identifying, preventing, and reporting money laundering, trade-based financial crime, and suspicious customer activity.
Establishing effective, risk-based internal controls tailored to physical trading, wholesale sourcing, and retail transactions.
Directing resources toward higher-risk products, services, high-value transactions, and client profiles.
Integrating national AML/CFT Priorities directly into your operational risk assessment process.

Independent Testing & Program Verification

An effective BSA AML/CFT program requires periodic independent testing. D1C partners with SIRS AML Compliance Services, our provider of choice and premier partner for independent testing services.

When your bank’s compliance department or a regulator requires an independent audit of your AML/CFT program, SIRS delivers a collaborative, thorough review and actionable audit report to demonstrate complete regulatory compliance.

Learn More About SIRS Independent Testing Services for Precious Metals Dealers →

Frequently Asked Questions

Bank Reviews & BSA/AML Regulatory Compliance

Why is my bank or wholesaler demanding a risk-based AML program and risk assessment process for my precious metals business?

Answer: Financial institutions and major wholesalers face immense regulatory pressure under FinCEN guidelines to monitor high-risk merchant relationships. Because precious metals and stones are highly liquid, banks require dealers to prove they maintain a compliant, risk-based AML program under 31 CFR 1027.210. Division One Compliance (D1C) provides dealers with custom risk assessments and tailored AML policy manuals that explicitly satisfy bank underwriting and wholesaler compliance departments, protecting your critical banking and supply chain relationships.

What are the key AML/CFT requirements under FinCEN 31 CFR 1027 for precious metals dealers?

Answer: Under 31 CFR 1027, dealers buying and selling covered goods (exceeding regulatory thresholds) must maintain a written AML program based on a documented risk assessment, train personnel annually, and provide for independent testing. D1C delivers an all-in-one compliance suite designed specifically for precious metals dealers, replacing overwhelming regulatory jargon with clear, concise, and easily implementable compliance tools.

How does Division One Compliance build a custom AML risk assessment tailored to precious metals dealers?

Answer: D1C evaluates your specific business model—including wholesale sourcing, retail sales, bullion trading, customer types, and geographic footprint—to document your unique money laundering and terrorist financing risks. Rather than handing you a generic template, D1C builds a personalized risk assessment that serves as the solid foundation for your customized AML policy manual and risk assessment process.

What AML/CFT training is required for staff in the precious metals industry?

Answer: FinCEN mandates annual AML/CFT training for personnel who handle purchases, sales, or compliance duties in precious metals businesses. D1C provides concise, targeted training modules that address specific precious metals risks—such as large cash transactions, red-flag customer behaviors, and trade-based money laundering—completable in minutes while ensuring full regulatory compliance.

How do D1C and SIRS AML Compliance Services ensure our precious metals business passes bank reviews?

Answer: Together with SIRS AML Compliance Services (www.sirsco.com), D1C offers a seamless, end-to-end solution including custom risk assessments, concise policy manuals, staff training, and independent testing. We provide the precise documentation and independent audit verification required by bank risk departments, giving your financial institution total confidence in your business operations.

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Ready to implement a personalized, cost-effective compliance program? Provide your information below, and we will respond quickly to your request.

By submitting this form, you agree that D1C may share your request details with our affiliate partner, SIRS AML Compliance Services, for the purpose of evaluating and responding to your request.