Last Updated June 2026
Anti-Money Laundering (AML) & USA PATRIOT Act Compliance
Alloy Market maintains a comprehensive anti-money laundering program designed to prevent financial crime, support regulatory compliance, and protect the integrity of the precious metals marketplace.
AML Program
Risk-based program aligned with Bank Secrecy Act requirements.
Identity Verification
Verification procedures for qualifying transactions.
Regulatory Cooperation
Cooperation with FinCEN and federal law enforcement.
Our Commitment
It is the strict policy of Alloy Market Inc. to prohibit and actively prevent money laundering, terrorist financing, and any criminal activity that facilitates either, by complying fully with all applicable requirements under the Bank Secrecy Act and its implementing regulations.
As a digital precious metals dealer, we recognize our role in safeguarding the integrity of the financial system. We maintain a comprehensive, risk-based anti-money laundering program approved by senior management.
What Is Money Laundering?
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that they appear to originate from legitimate sources or to constitute legitimate assets. It typically occurs in three stages:
- Placement: Introducing illicit cash into the financial system.
- Layering: Moving or converting funds through various transactions to separate them from their criminal origin.
- Integration: Reintroducing the “clean” funds into the economy to purchase legitimate assets.
While terrorist financing may involve legitimate funds (e.g., business earnings or charitable donations) rather than criminal proceeds, the methods used to obscure the source or ultimate destination of these funds mirror those used in traditional money laundering. Alloy Market monitors for both activities with equal diligence.
How Alloy Reduces Risk
Why We May Request Identification
State and federal regulations require us to verify customer identities in certain situations. Identification verification helps:
Individual Customers
For high-risk sales or transactions exceeding $10,000 in a calendar year, we verify customer identity by reviewing and maintaining a copy of:
- Full legal name
- Physical address
- Government-issued photo identification
- Additional supporting information when appropriate
Business Partners & Suppliers
For transactions exceeding $20,000 in a calendar year, we verify from an established or non-established supplier the legal entity’s existence by reviewing:
- Legal business name
- EIN or Tax ID
- Organizational documents
- Verification of business operations
- AML compliance documentation
Why am I being asked for ID?
Identity verification is a standard compliance practice throughout the financial services and precious metals industries. These procedures help protect both customers and businesses from fraud and financial crime.
Suspicious Activity Monitoring
Alloy Market continuously monitors transactions for red flags and indicators of unusual activity. We exercise enhanced due diligence in scenarios involving:
- Unusual payment structures or third-party payment methods.
- An unwillingness by a customer or supplier to provide complete, accurate verification information.
- Attempts to maintain an unusual degree of secrecy or requests to circumvent standard recordkeeping.
Our designated AML Compliance Officer reviews all high-risk activity. Alloy Market reserves the right to delay, decline, withdraw from, or terminate transactions that cannot be adequately verified or that appear inconsistent with applicable laws or regulations.
Regulatory Cooperation
Alloy Market cooperates fully with state and federal law enforcement agencies and regulatory bodies, including the Financial Crimes Enforcement Network (FinCEN).
- Section 314(a) Requests: We process and comply with Section 314(a) requests issued under the USA PATRIOT Act expeditiously.
- Regulatory Reporting: Where required by law, Alloy Market files appropriate documentation with the Department of the Treasury. In certain circumstances involving potentially suspicious activity, we may voluntarily provide information to law enforcement or regulatory authorities as permitted by applicable law.
- Confidentiality: In strict accordance with federal law, if a Suspicious Activity Report is generated or filed, Alloy Market is legally prohibited from disclosing this fact to any person involved in the transaction.
- Chapter 501: State requirements under Chapter 501 for the precious metal license ensure that Alloy captures records of every transaction, including specific information around client identity
Program Governance
Our AML program is supported by the following key components:
Compliance Officer
A dedicated, qualified AML Compliance Officer vested with full authority to enforce our internal controls. They serve as our primary point of contact for all regulatory bodies.
Employee Training
Twice annual, mandatory training for all relevant personnel regarding BSA regulations, industry risk profiles, and suspicious activity detection. We maintain strict, confidential pathways for internal compliance reporting.
Record Retention
All data collected for identity verification, transaction reviews, and regulatory filings are securely archived and retained for a minimum of five (5) years.
