Certified Gold Exchange Anti-Money Laundering & Anti-Terrorist Financing Compliance Program

Certified Gold Exchange, Inc. (CGE) is committed to preventing money laundering, terrorist financing, sanctions violations, and other illegal financial activities. Since 1992, our business has operated on the principle that protecting our customers, maintaining accurate records, and conducting lawful precious-metals transactions are fundamental responsibilities—not optional business practices.

Written by John J. Halloran, Founder & CEO and Lead AML Compliance Officer | Certified Gold Exchange, Inc. | Founded in 1992 | 5.0 Google Review Rating | A+ BBB Rating with Zero Complaints | Serving 58,000+ Investors in All 50 States Since 1992

Original compliance program revised October 2, 2023. Public-facing policy updated October 2026.

Our Commitment to Financial Integrity

Certified Gold Exchange maintains a risk-based Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) compliance program designed to identify suspicious transactions, prevent unlawful financial activity, and protect the integrity of our precious-metals operations.

Our policies apply to employees, independent contractors, authorized representatives, and other parties acting on behalf of CGE, as appropriate to their responsibilities.

We do not knowingly conduct business with individuals or organizations involved in money laundering, terrorist financing, sanctions evasion, fraud, or other illegal activities.

FinCEN and Bank Secrecy Act Compliance

The Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, administers federal requirements designed to combat money laundering and other financial crimes.

Under the Bank Secrecy Act and 31 CFR § 1027.210, covered precious-metals dealers must establish written AML programs appropriate to their business activities and risk exposure.

The regulation establishes four essential components:

1. Risk-based policies, procedures, and internal controls designed to address money laundering and terrorist financing risks.
2. A designated compliance officer responsible for implementing and maintaining the program.
3. Ongoing training for personnel whose responsibilities may involve identifying or preventing suspicious transactions.
4. Independent testing to evaluate whether the program operates effectively.

CGE maintains policies addressing these elements and reviews them as its business activities, regulatory obligations, and identified risks evolve.

Official reference: FinCEN — Anti-Money Laundering Requirements for Precious-Metals Dealers.

Understanding Money Laundering and Terrorist Financing

Money laundering generally involves concealing or disguising proceeds from unlawful activity to make those funds appear legitimate. Financial criminals may attempt to exploit precious metals because certain products can retain substantial value and be transferred or resold.

Money laundering is commonly described in three stages:

1. Placement

Illegally obtained funds are introduced into the financial system or used to purchase assets. These transactions may involve attempts to disguise the origin or beneficial ownership of money.

2. Layering

Funds or assets are moved through transactions intended to obscure their source. This can include transfers among accounts, entities, or asset classes that make financial activity difficult to trace.

3. Integration

Illicit proceeds are reintroduced into the legitimate economy through apparently lawful assets or business transactions.

Terrorist financing may involve funds originating from lawful or unlawful sources. Accordingly, CGE’s compliance program addresses suspicious activity involving both the origin and intended use of funds.

CGE’s Designated AML Compliance Officers

John J. Halloran — Lead AML Compliance Officer

As CGE’s founder and chief executive officer, John J. Halloran is responsible for overseeing the company’s AML policies, compliance standards, team training, and escalation procedures.

Yaneth Villalon — Secondary AML Compliance Officer

Yaneth Villalon provides additional compliance oversight and assists with policy administration, training, and internal reviews.

Both have completed anti-money laundering coursework through the London Institute of Business & Management.

View AML Training Certificates.

The compliance function is authorized to investigate potentially suspicious activity, require additional documentation, decline transactions, and determine appropriate escalation procedures.

Independent AML Program Reviews

CGE’s AML program provides for independent testing at least annually as an internal company standard, subject to review of applicable regulatory requirements and business risks.

Independent reviewers assess whether our written procedures are being followed and whether identified compliance risks are appropriately addressed.

Reviews may cover customer identification, transaction documentation, recordkeeping, staff training, payment controls, sanctions screening, and suspicious-activity procedures.

Independent testing must be performed by a qualified person who is not responsible for operating the AML program being reviewed. Findings requiring corrective action are referred to management for resolution.

CGE’s Risk Assessment and Internal Controls

1. Geographic and Jurisdictional Risk

CGE principally serves customers through U.S.-based precious-metals transactions and established domestic financial channels.

Geographic risk is evaluated according to the individuals, counterparties, jurisdictions, payment routes, and delivery arrangements involved.

We recognize that domestic transactions are not automatically risk-free. When circumstances warrant, additional scrutiny may be applied to unfamiliar counterparties, unusual transaction patterns, or potential sanctions concerns.

2. Customer and Counterparty Identification

CGE is not an anonymous, automated precious-metals marketplace. Our transaction process involves direct communication with customers and appropriate verification procedures.

Depending on the transaction and applicable requirements, our team may request:

• Customer identification and contact information.
• Information concerning the source of transaction funds.
• Verification of the intended account or payment beneficiary.
• Information about business entities, trusts, or authorized representatives.
• Additional documentation where activity presents elevated compliance concerns.

We may decline a transaction when necessary information cannot be obtained or suspicious circumstances remain unresolved.

3. Precious-Metals Product Risk

CGE primarily recommends widely recognized investment products, including American Gold and Silver Eagles, Canadian Gold and Silver Maple Leafs, and qualifying bullion bars.

Our risk assessment considers the type of product, transaction size, counterparty, payment method, and relevant purchase or resale circumstances.

No precious-metal product is inherently immune from misuse. Accordingly, familiar bullion products remain subject to appropriate compliance controls.

4. Accepted Payment Methods

CGE does not accept physical cash for precious-metals purchases.

Approved payment methods include eligible personal checks, bank wires, and ACH transfers through accepted banking arrangements, subject to verification and transaction requirements.

We do not ordinarily accept third-party payments or payments from unidentified parties. Transactions involving trusts, corporations, or other entities may require additional verification.

5. Gold IRA Transactions

CGE facilitates customer-directed purchases and liquidations involving self-directed precious-metals IRAs.

Qualified retirement-account custodians administer these accounts, while authorized depositories provide storage arrangements.

CGE coordinates appropriate transaction documentation and works with custodians and depositories to support proper account administration.

Custodian involvement does not eliminate CGE’s responsibility to assess risks within its own business activities.

For additional information, visit our Gold IRA Guide and Gold IRA Custodians Guide.

6. Precious-Metals Buybacks and Liquidations

When purchasing precious metals from customers, CGE may request identification, ownership information, account documentation, and details concerning the original acquisition.

Our procedures are intended to verify the legitimacy of the transaction and identify circumstances requiring additional review.

Payments are made through approved methods consistent with applicable requirements.

Learn more about Selling Precious Metals From a Gold IRA.

Enhanced Review of Higher-Risk Transactions

Transactions presenting unusual characteristics may require additional information before CGE proceeds.

Potential warning signs include inconsistent identification, unexplained payment arrangements, unusual transaction structures, reluctance to disclose relevant information, or attempts to conceal beneficial ownership.

Depending on the circumstances, CGE may request additional documentation, seek clarification, escalate the matter to its AML compliance officer, suspend processing, or decline the transaction.

All decisions are made in accordance with applicable law and CGE’s internal risk-management policies.

Sanctions Screening and OFAC Compliance

CGE maintains procedures intended to prevent prohibited transactions involving sanctioned persons, entities, or jurisdictions.

Where appropriate, customer and counterparty information may be reviewed against sanctions information published by the U.S. Treasury’s Office of Foreign Assets Control (OFAC).

Potential matches are evaluated before any required action is taken. Screening results and relevant decisions are documented in accordance with applicable procedures.

Official resource: OFAC Sanctions Search.

Monitoring and Reporting Suspicious Activity

CGE monitors transactions for unusual activity consistent with its risk-based compliance procedures.

Our compliance officers evaluate suspicious circumstances, review relevant documentation, and determine appropriate action.

Depending on applicable requirements and the circumstances involved, CGE may contact law enforcement, make authorized reports to FinCEN, or decline to proceed with a transaction.

FinCEN’s precious-metals dealer AML rule does not impose a general mandatory Suspicious Activity Report filing requirement equivalent to that applicable to certain other financial institutions. However, FinCEN encourages appropriate voluntary reporting and cooperation with law enforcement.

CGE complies with applicable mandatory reporting requirements and evaluates voluntary reporting when justified.

We also recognize the importance of maintaining the confidentiality of legally protected reporting information.

Recordkeeping and Documentation

CGE maintains transaction and compliance records in accordance with applicable law and its document-retention policies.

Depending on the circumstances, records may include customer identification, transaction details, payment information, product descriptions, supporting documentation, internal reviews, and the resolution of relevant discrepancies.

Record-retention periods are determined by the requirements applicable to the specific records and activities involved.

CGE does not claim that every precious-metals transaction is subject to bank or broker-dealer customer-identification rules that may not apply to its business.

Employee and Contractor Training

CGE provides compliance training appropriate to each team member’s responsibilities.

Training addresses identification of suspicious activity, customer verification, payment safeguards, sanctions concerns, internal escalation, and reporting procedures.

Team members are expected to recognize potential warning signs and promptly refer concerns to the designated compliance officer.

Deliberately ignoring suspicious circumstances or circumventing established controls is inconsistent with CGE’s compliance standards.

Our Customer Agreement and Lawful Funds Requirement

CGE requires customers to conduct transactions using funds and assets obtained through lawful activities.

Our customer agreement includes representations concerning legitimate ownership, lawful intent, and compliance with applicable anti-money laundering and counter-terrorist financing requirements.

CGE reserves the right to request additional documentation or decline transactions when necessary to satisfy legal obligations or established risk-management standards.

Precious-Metals Tax Reporting

Certain precious-metals sales may trigger federal information-reporting requirements, including Form 1099-B, depending on the product, transaction characteristics, and applicable IRS rules.

Not every sale of gold or silver automatically requires Form 1099-B reporting, and customers should not confuse information reporting with the separate question of whether a transaction produces a taxable gain.

Customers should consult their own qualified tax professionals regarding individual reporting and tax obligations.