Anti Money Laundering Policy

Heights Jewelers LLC Anti Money Laundering Policy

 It is the policy of Heights Jewelers LLC to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements.


Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. 


Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

AML Compliance Person Designation and Duties

Heights Jewelers LLC has designated our current CFO, Dr. Deniz Appelbaum PhD, a recognized authority in the use of blockchain to verify the origin of assets and minerals, as its Anti-Money Laundering Program Compliance Person, with full responsibility for Heights Jewelers LLC’s AML program.   Dr. Appelbaum is qualified published research as a recognized authority and source person in the field and is sought by multinational firms. The duties of the AML Compliance Person will include monitoring Heights Jewelers LLC’s compliance with AML obligations and overseeing communication and training for employees. The AML Compliance Person will also ensure that Heights Jewelers LLC keeps and maintains all of the required AML records and will ensure that Suspicious Activity Reports are filed when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce Heights Jewelers LLC’s AML program. 

Giving AML Information to Federal Law Enforcement Agencies

We will respond to a Request for information from local or federal police and cooperate fully in accord with the Patriot Act.  If our record search does not find a matching account or transaction, we will maintain documentation that we have performed the search.


We will direct any questions we have about the Request to the requesting federal law enforcement agency as designated in the request.   

Voluntary Information Sharing With Other Institutions under USA PATRIOT Act

We will share information with other appropriate institutions regarding individuals, entities, organizations and countries for purposes of identifying and, where appropriate, reporting activities that we suspect may involve possible terrorist activity or money laundering. Our CFO will ensure that Heights Jewelers LLC files with local law enforcement an initial notice before any sharing occurs and annual notices thereafter. We will take reasonable steps to verify that the other institution has submitted the requisite based upon reasonable and proper grounds,

Supplier Compliance Program

We will only purchase precious metals from firms known to be in compliance with and show evidence of compliance with an anti-money laundering program.

Suppliers Who Refuse to Provide Information

If a potential or existing supplier either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our firm will cease all activities with this firm. 

Verifying Information

We will use standard JVC guidelines in verifying firms and their compliance. Based on the purchase, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true money trail.  We will verify the information within a reasonable time before or after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we may, pending verification, restrict the types of transactions. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we will, after internal consultation with Heights Jewelers LLC's AML Compliance Person notify proper law enforcement.

Comparison with Government-Provided Lists of Terrorists

At such time as we receive notice that a federal government agency has issued a list of known or suspected terrorists and identified the list as a list for manufacturers, we will, within a reasonable period of time after an account is opened determine whether a supplier appears on any such list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by Treasury in consultation with the federal functional regulators. We will follow all federal directives issued in connection with such lists.   

Reliance on Another Institution for Verification

We may rely on the information provided by another manufacturer of some or all of the elements of our due diligence, if said supplier is known to be in compliance, and has presented evidence of such compliance.


Summons or Subpoena of Records; Termination of Relationships

When we receive a written request from a federal law enforcement officer for information identifying suspected money laundering, we will provide that information to the requesting officer not later than seven days after receipt of the request. We will close, within 10 days, any account learn from the Department of Justice has failed to comply with a summons or subpoena issued by the Secretary of the Treasury or the Attorney General of the United States or has failed to contest such a summons or subpoena.

Monitoring Suppliers for Suspicious Activity

We will monitor activity for unusual size, volume, pattern or type of transactions.

Emergency Notification to Law Enforcement by Telephone

In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately call an appropriate law enforcement authority. If a company appears on a watch or terrorist list, we will call the OFAC Hotline at (800) 540-6322

Responding to Red Flags and Suspicious Activity

When an employee of Heights Jewelers LLC detects any red flag, or other activity that may be suspicious, he or she will notify our CFO. Under the direction of the AML Compliance Person, Heights Jewelers LLC will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources or contacting the government.

AML Recordkeeping

Our AML Compliance Person and their designee will be responsible for ensuring that AML records are maintained properly.

Training Programs

Our training will include, at a minimum a training seminar provided by our AML Designee: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags.



Part of our training program is that all employees must view the You Tube videos entitled “Anti Money Laundering in the Jewelry Industry”, “Anti Money Laundering – AML” and “How Does Money Laundering Work? Within two weeks of being hired.  Each employee must submit a statement that he has viewed such video and the date.

 Monitoring Employee Conduct and Accounts

We will subject employee accounts to the same AML procedures as customer accounts, under the supervision of the AML Compliance Person. We will also review the AML performance of supervisors, as part of their annual performance review. The AML Compliance Person’s accounts will be reviewed by the CFO

Confidential Reporting of AML Non-Compliance

Employees will promptly report any potential violations of Heights Jewelers LLC’s AML compliance program to the AML Compliance Person, unless the violations implicate the AML Compliance Person, in which case the employee shall report to [the president/chairman of the board/audit committee chair]. Such reports will be confidential, and the employee will suffer no retaliation for making them.

Additional Risk Areas

Heights Jewelers LLC has reviewed all areas of its business to identify potential money laundering risks.

 Senior Manager Approval

Senior management has approved this AML compliance program in writing as reasonably designed to achieve and monitor our firm’s ongoing compliance with the requirements of the Patriot Act.


Complaints and notifications

Andy complaints and notifications of violations can be reported to senior management at