Why bother with integrating AML Compliance for any Jewellery Company? To gain some context feel free to read a brief introduction in our services section. The Jewellery, Precious Metals & Stones industry current falls under the ambit of the Narcotics Division, whom according to their information booklet created in 2008, “…is still deliberating the best regulatory model for your professions.” As they continue their deliberation which has officially passed the 10 year mark, the global arena has changed dramatically and local dynamics have been effected as a result.
Realising the changing environment is the first step, and companies that are able to stay ahead of the pack are expert at this. Then is the proactive question of how to react and evolve in an effort to adapt and grow. This is why Jewellery companies, despite the lack of laws have begun learning and integrating AML compliance, because prevention is better than cure. To add to this is the current climate of banks and other institutions de-risking or not even serving jewellery companies. These questions and issues were raised by a prominent online jewellery retailer who approached us not too long ago. The first step for us was to collect data to ascertain:
- Basic details, size, and resources of the company
- Current structure, protocols, and workflow
- Clients, suppliers, goods, services, and assess inherent risks
- Future plans and goals
- Any specific request, issues, or concerns
With this information in hand we collaborated with them to create workflow and policies that incorporated AML compliance practically, realistically, and we personally checked all their accounts in return for our signature of full compliance with their stated policies. We agreed to re-check their system personally in 3 years time or when changing circumstances required it. Our signature of compliance was a special request on their part, something we usually only reserve for an Anti-Money Laundering Audit. Given the strenuous process of an AML audit, their relatively simple business model and workflow, their current lack of relative risk exposure, and absent laws in Hong Kong, we saved them time and resources by signing off with a compliance note in their AML manual instead.
AML compliance takes time to learn and incorporate, by taking the first steps the company has gained an idea about the topic and how to turn it into their competitive advantage. They also have a policy manual that is expertly created and signed by a professional company verifying that they are actually following their stated policies. Its applications include providing proof to financial institutions to allay their fears, Third Party Payment Processors (TPPPs) such as Pay Pal and Stripe who have become more sensitive to Jewellery Companies from Hong Kong, address any concerns that businesses from other jurisdictions might have, and simply preparing the company for the future, when laws and regulations in Hong Kong are eventually implemented.