Dealers are warned not to pay customers with more than one check in a transaction in the latest issue of the Industry Council for Tangible Assets’ online Washington Wire.
Such an action might be construed by banks or government authorities as “illegal structuring” that would assist someone trying to evade tax and transaction reporting requirements. Cited was the experience of an unnamed dealer whose bank unilaterally closed his accounts after 10 years of doing business with him most likely for issuing multiple checks.
ICTA suggests that a firm’s policy should be one purchase order, one check and that this policy be written into the Anti-Money Laundering policy that is required by law.
To contact ICTA, email Eloise Ullman, executive director, at Eloise.Ullman@ictaonline.org.
ICTA is the voice of coin and precious metals dealers in Washington, D.C., and in various state capitals where sales taxes become an issue.