AML — ANTI-MONEY LAUNDERING
AML law does not live in a spreadsheet.
MetalDesk turns a precious metals dealer's statutory obligations into software: identification and due diligence, risk assessment, ongoing monitoring, sanctions screening, suspicious activity reporting and five-year retention — all inside a sealed audit chain.
WHY AML ON METALDESK
Obligations are met as the work happens.
AML law forgives nothing: a missing due diligence record, an unscreened name or an undocumented risk assessment all read as failures in a supervisory inspection. MetalDesk enforces the correct order on every purchase.
- 01
Identification in under a minute
The ID is scanned at the counter, due diligence data and date of birth are stored, and the customer signs electronically on the same device. The document lives in restricted, encrypted storage.
- 02
Risk-based assessment
Every customer gets a risk rating from country, product, payment method, trading frequency and amounts. High risk triggers enhanced due diligence before any payout.
- 03
Ongoing monitoring and anomaly alerts
The system detects structuring below thresholds, unusual volume spikes and repeat cash trades, and re-screens the whole customer base whenever sanctions lists change.
- 04
Reporting duty and a sealed chain
A suspicious transaction is flagged, the payout is blocked and a report package is assembled for the Financial Intelligence Unit. Every step is chained with a SHA-256 digest.
WHAT THE LAW REQUIRES
Every statutory duty — and where it happens in the system.
A dealer in precious metals is an obliged entity once a cash transaction reaches EUR 10,000, including linked instalments. In practice the whole operation is built so the duties are satisfied on every trade. Duty by duty below.
- 01 · CDD — identification
Identify and verify the customer
The customer must be identified before the business relationship or occasional transaction. Name, identity number or date of birth, address and document details must be recorded.
IN METALDESK
ID scanning, customer registry, electronic signature
- 02 · CDD — beneficial owner
Beneficial ownership and authority to act
For corporate customers the beneficial owner must be established and the representative's authority verified.
IN METALDESK
Corporate due diligence fields and beneficial owner record
- 03 · EDD — PEP
PEP status and enhanced due diligence
Politically exposed persons, their family members and close associates require enhanced measures and senior management approval.
IN METALDESK
PEP flag, EDD queue, mandatory approval before payout
- 04 · Source of funds
Establish the origin of funds
For unusual or large transactions the source of funds and wealth must be established and documented.
IN METALDESK
Source-of-funds field, mandatory above thresholds
- 05 · Ongoing monitoring
Monitor the relationship continuously
Transactions must be monitored to confirm they remain consistent with the known customer profile.
IN METALDESK
Behavioural alerts, volume spikes, structuring detection
- 06 · Sanctions regulations
Sanctions screening and asset freezing
Funds must never be made available to a listed person. Both customer and payee must be screened before settlement.
IN METALDESK
EU, OFAC and UK screening plus IBAN blocking before payment runs
- 07 · SAR / STR
Report suspicious activity
Suspicious transactions must be reported to the FIU without delay, and the customer must not be told (no tipping off).
IN METALDESK
Report package assembly, payment block, confidentiality-safe UI
- 08 · Retention
Retain records for five years
Due diligence data and transaction documents must be retained for five years after the relationship or transaction ends.
IN METALDESK
Immutable storage with automatic retention calculation
- 09 · Governance
Business risk assessment and internal controls
An obliged entity must maintain a written risk assessment, internal procedures, staff training and a whistleblowing channel.
IN METALDESK
Risk assessment document, role-based access, training log
- 10 · Dealer register
Purchase register and authority disclosure
Purchases of second-hand goods and precious metals must be recorded in a purchase register and disclosed to authorities on request.
IN METALDESK
Police book export with checksum, audit package ZIP
The same structure applies in Sweden (penningtvättslagen 2017:630), Germany (GwG, precious metals from a EUR 2,000 cash threshold) and the UK (MLR 2017 with HMRC High Value Dealer registration). MetalDesk selects the right rule pack from the location's country.
THE EU'S NEW AML RULEBOOK
The 2027 AML package: one rulebook for the whole union.
In 2024 the EU adopted a full overhaul: a directly applicable AML Regulation (AMLR, (EU) 2024/1624), the sixth AML Directive ((EU) 2024/1640) and a new EU-level supervisor, AMLA ((EU) 2024/1620, seated in Frankfurt). National interpretation gaps disappear — the obligations come straight from the regulation and apply to precious metals dealers in full.
- 2025
AMLA starts operating
The EU Anti-Money Laundering Authority is established in Frankfurt and begins drafting the technical standards that harmonise due diligence and reporting across the union.
- 10 Jul 2027
AMLR and AMLD6 apply
The regulation applies directly in every member state, and member states must have transposed the directive by the same date.
- EUR 10,000
Union-wide cash payment cap
Traders may not accept cash payments above EUR 10,000. Member states may set a lower limit — Germany already applies a stricter threshold to precious metals.
- EUR 3,000
Identification threshold for occasional trades
Dealers in precious metals and stones must identify the customer in cash transactions from EUR 3,000 where there is no ongoing business relationship.
- 2028
Direct AMLA supervision
AMLA begins direct supervision of selected entities and coordinates national supervisors. Inspections will focus on the ability to produce documented, unbroken evidence.
MetalDesk is already built for this: country-specific rule packs, automatic threshold enforcement, cash-limit blocking, machine-readable report packages and a one-click audit pack containing the purchase register, due diligence records, screening evidence, batch seals and the change log with chained digests.
LIVE COMPLIANCE DATABASES
Sanctions and embargo lists update automatically.
Sanctions screening is an obligation that expires daily. MetalDesk syncs the official lists centrally: when the EU publishes a new regulation today, every customer's screening uses the new data within minutes.
- EUDaily at 06:00 UTCEU Consolidated Financial SanctionsEuropean Council data.europa.eu
- USDaily at 06:15 UTCOFAC SDN (Specially Designated Nationals)US Treasury OFAC
- UKDaily at 06:30 UTCUK HM Treasury Consolidated ListGOV.UK OFSI
- IBANReal-timeMetalDesk embargo IBAN blocklistInternal risk database
Every sync is written to the audit log. You always see when a list was last updated, how many records changed and where the data came from.
LEGAL DOCUMENTS
Policies built to survive an audit.
Full policies covering due diligence, AML, sanctions, accounting integrations (Fivaldi, Netvisor) and data retention.
This page describes software functionality in general terms and is not legal advice. Responsibility for meeting the obligations always remains with the obliged entity.
Security & compliance
Audit-ready. No more weekends with the auditors.
KYC, 2FA, sanctions screening and a complete audit trail. A single fine or after-the-fact investigation costs many times a year of MetalDesk. We log every decision for you.
Audit coverage
Built-in by default
Costs a year of license
First month free · Cancel anytime