Compliance & Policies

IRS Reporting Requirements (Form 1099-B)

Under Internal Revenue Service (IRS) regulations, precious metals dealers are required to report certain transactions to the IRS using Form 1099-B. The following transactions are reportable:

• Gold: Sales of 25 or more ounces of gold bars, gold maple leafs, gold krugerrands, or gold Mexican onzas in a single transaction or related transactions within 24 hours.
• Silver: Sales of 1,000 ounces or more of silver bars or silver rounds in a single transaction or related transactions within 24 hours.
• Platinum/Palladium: Sales of 25 or more ounces of platinum or palladium bars in a single transaction or related transactions within 24 hours.

Bank Secrecy Act Compliance

Goldman Fischer Metals Desk complies with the Bank Secrecy Act (BSA) and its implementing regulations. As a dealer in precious metals, we are required to:

• Currency Transaction Reports (CTR): File FinCEN Form 112 for cash transactions exceeding $10,000 in a single day.
• Customer Identification Program (CIP): Verify the identity of customers making purchases of $3,000 or more.
• Recordkeeping: Maintain records of transactions and customer identification for at least five years.

Note: Other required reports may be filed as mandated by applicable federal and state regulations.

USA PATRIOT Act Compliance

In accordance with the USA PATRIOT Act and FinCEN regulations (31 CFR 1027), dealers in precious metals are required to establish and maintain an effective anti-money laundering (AML) program. Our AML program includes:

• Policies, procedures, and internal controls designed to ensure compliance
• Designation of a compliance officer responsible for day-to-day compliance
• Ongoing employee training program
• Independent testing of the AML program
• Risk-based procedures for conducting ongoing customer due diligence

OFAC Sanctions Compliance

Goldman Fischer Metals Desk complies with all sanctions programs administered by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury. We screen all customers against OFAC's Specially Designated Nationals (SDN) List and other relevant sanctions lists. We do not conduct business with sanctioned individuals, entities, or countries.

FTC Trade Regulation Compliance

We comply with the Federal Trade Commission's regulations regarding precious metals sales, including:

• Truthful advertising and marketing practices
• Clear disclosure of all material terms and conditions
• Accurate representation of product quality and authenticity
• Prohibition against deceptive pricing practices