Your AML program, made simple.
If you buy and sell enough gold, diamonds or jewelry, FinCEN requires a written anti-money-laundering program. FineVault AML will give you the written policy, risk assessment, procedures and staff training, all built around 31 CFR Part 1027 and written for a jewelry counter, not a bank.
Planned from $49/month. Staff training included. Everything by email and online, no sales calls.
Who it's for
Businesses that may meet FinCEN's definition of a "dealer" in precious metals, precious stones or jewels.
Independent jewelers
Especially stores that buy scrap gold, estate pieces or loose stones from the public.
Gold & silver buyers
Cash-for-gold counters, refiners' buying desks and walk-in buyers.
Bullion & coin dealers
Shops trading bars, rounds and numismatic items with significant metal value.
Wholesalers & manufacturers
Suppliers buying and selling covered goods between businesses.
Multi-store groups
Several locations that need one program with a risk view for each store.
Pawn shops that also buy jewelry
Pawn transactions are excluded, but outright jewelry and gold purchases may not be.
31 CFR 1027.100(b)(2)(ii)The quick test. Under 31 CFR 1027.100(b), you're generally a covered dealer if, in the prior calendar or tax year, you both bought more than $50,000 and sold more than $50,000 of covered goods. Retailers are covered only if they bought more than $50,000 of covered goods from people other than dealers or retailers, such as members of the public. A retailer's program can then focus on those purchases (31 CFR 1027.210(a)(2)).
What's included
Each piece maps to a requirement in FinCEN's dealer program rule, 31 CFR 1027.210. You fill in your details and adopt it as your own.
Written AML policy
A complete policy for senior management to approve, including the compliance-officer designation and duties.
31 CFR 1027.210(a), (b)(2)Risk assessment
A guided worksheet covering your products, customers, suppliers, sales channels and locations.
31 CFR 1027.210(b)(1)(i)ID & recordkeeping procedures
Counter-ready steps for identifying sellers, making reasonable inquiries, handling cash over $10,000 (Form 8300) and keeping records for five years.
31 CFR 1027.210(b)(1)(ii), 1010.330, 1010.430Red-flag guide
The warning signs FinCEN lists, with jewelry-store examples and what to do when one shows up.
31 CFR 1027.210(b)(1)(ii)Independent-testing checklist
A step-by-step checklist for your tester. An employee or officer can do the testing, as long as they aren't your compliance officer and aren't involved in running the program.
31 CFR 1027.210(b)(4)Jeweler-specific staff training
Short online lessons for counter staff, with completion records. Included in every plan, not sold per seat.
31 CFR 1027.210(b)(3)How it will work
Answer a short online questionnaire
What you buy, who you buy from, how you get paid, and where you operate.
Get your tailored documents
Policy, risk assessment and procedures, ready to edit and sign.
Train your staff online
Short lessons with a completion log you keep for your own records.
Stay current
Yearly review reminders and an independent-testing checklist when it's due.
Simple pricing
Planned launch pricing. Staff training is included in every plan. Items marked "planned," including month-to-month billing you can cancel anytime, aren't available yet. Waitlist members hear first.
Starter
- One store location
- Full written AML program
- Guided risk assessment
- Red-flag guide & procedures
- Staff training included
- Email support
Pro
- Everything in Starter
- Independent-testing workbook & findings log
- Training completion records for every employee
- Annual program refresh (planned)
- Priority email support (planned)
Multi-store
- Everything in Pro
- Up to 5 locations (planned)
- A risk assessment for each location
- One program, one compliance officer view
- Priority email support (planned)
How we compare
| FineVault AML Starter | JewelPAC | |
|---|---|---|
| First year | $490 (planned annual plan) | $750 |
| Each year after | $490 (planned) | $500 renewal |
| Employee training | Included | $50 per additional employee |
| Billing | Monthly or annual | One-time purchase plus yearly renewal |
JewelPAC prices are from Jewelers Mutual Group's JewelPAC FAQ, checked October 19, 2026: First-Time Full Bundle $750; Employee Training Bundle $50 "to train an additional employee" (requires a completed First-Time Full Bundle); Annual Renewal Bundle $500, which can be bought 9 to 18 months after your last completed bundle. Check their site for current prices and terms. JewelPAC is a product of the Jewelers Vigilance Committee and Jewelers Mutual Group. FineVault AML is not affiliated with either.
Join the waitlist
We'll email you when FineVault AML opens. We plan to offer founding-member pricing to the waitlist. Email only. No calls.
Questions
Do I actually need an AML program?
Possibly. It depends on how much you buy and sell, and who you buy from. See the thresholds in 31 CFR 1027.100(b) and our plain-English guide. If you're unsure, ask your attorney or accountant.
Is this legal advice?
No. FineVault AML provides templates, guidance and training. It isn't a law firm. You adopt and run your own program, and you should have counsel review it if you have questions about your situation.
Do you file reports such as Form 8300 for me?
No. We show your staff when a report is needed and how to file it. Your business files its own reports.
Can I talk to someone?
All sales and support are by email and online forms, so every answer is written down for your records. Email support@finevaultaml.com.
Is training really included?
Yes. Staff training is part of every plan. There's no per-employee training fee.