patriot act 2 guidelines - money laundering
roadrunner
Posts: 28,313 ✭✭✭✭✭
I delved into this topic the past few hours and couldn't find anything yet on the actual written records of bullion type transactions required. However the anti-money laundering (AML) requirements and who is affected is very clear. The bill was created on behalf of licensed pawn brokers who were peed off that unlicensed brokers were stealing their business. Hence the licensed PB's are exempt.
The law requires that all "dealers" transacting $50k or more per year in PM's must maintain an AML program. The $50K is based on the previous year. So starting in 2006, it's based on one's purchases or sales in 2005.
A dealer is anyone transacting $50K or more per year with only these exceptions:
1. retailers who buy most of their goods from other wholesalers
(jewelers for example). A jeweler or coin dealer who buys $50k
worth of bullion from the public or sells the same amount is not
exempt.
2. licensed PB's.
3. those that transact (selling for buying) < $50K per year.
Hence, any collector or investor who buys or sells $50k in bullion per year would be considered a dealer and must maintain an AML program. Penalties for not doing so can reach $250K or 5 yrs.
In essence this includes an investor buying MS64 saints to the tune of say $100,000 per year (2-1 premium to gold for 64 Saints). Apparently trades do not count towards the totals. So if you wanted to roll your profits back and forth into numismatic coins you do not have to maintain an AML. A company like Heritage could accomodate you but would they have the numismatic coins that you want. No sense in taking well-earned profits and buying overgraded and conserved junk to avoid an AML program.
The proram is sort of ludicrous since a terrorist can trade in ill-gotten stolen coins for "legitamite" ones. Or a terrorist can take his cash booty and trade for MS65 Saints or other rare numismatic items which would be exempt. Then later sell those items for cash and avoid scrutiny.
To those on the forum who trade in PM's and generic $10's and $20's to the tune of over $100K per year, must maintain an AML program. This may not be so complicated if one only trades with say a few companies like Heritage, Blanchard or NGE. Your program could require that you only trade with these 3 firms (both purchases and sales), that you are the compliance officer, and then get an auditor to check it for content. Seems unlikely that you could be a target for terrorist laundering if you only deal with 3 of the most reputable firms in the country. Still, if one decides to safeguard their money from the ravages of FED induced inflation into PM's authorized by our constitution, you have to have an AML. While those that plop their $100K into stocks or other "good" investments, those that have a well earned distrust for paper assets are criminals
for considering PM's. The Patriot Act 2 AML provision is only the first step, the lack of M3 data from the FED is now the 2nd step, what will be next? All this looks like a concerted effort to destroy the PM market and prop up paper money further.
The fact that collectors and investors have to maintain such a program is ludicrous. Going rate for a canned program is $600 for
ICTA members and then $1000-$3000 for other firms who offer this.
My local dealer has signed up for the $600 program.
US Treasury AML link - bill #352
The above link has all you need to see. Nothing listed on how records are kept from buyers and sellers you deal with. Gee, if I buy $20 Saints from Heritage do I have to get Greg Rohan's fingerprints and SSN? Hmmmm?
roadrunner
The law requires that all "dealers" transacting $50k or more per year in PM's must maintain an AML program. The $50K is based on the previous year. So starting in 2006, it's based on one's purchases or sales in 2005.
A dealer is anyone transacting $50K or more per year with only these exceptions:
1. retailers who buy most of their goods from other wholesalers
(jewelers for example). A jeweler or coin dealer who buys $50k
worth of bullion from the public or sells the same amount is not
exempt.
2. licensed PB's.
3. those that transact (selling for buying) < $50K per year.
Hence, any collector or investor who buys or sells $50k in bullion per year would be considered a dealer and must maintain an AML program. Penalties for not doing so can reach $250K or 5 yrs.
In essence this includes an investor buying MS64 saints to the tune of say $100,000 per year (2-1 premium to gold for 64 Saints). Apparently trades do not count towards the totals. So if you wanted to roll your profits back and forth into numismatic coins you do not have to maintain an AML. A company like Heritage could accomodate you but would they have the numismatic coins that you want. No sense in taking well-earned profits and buying overgraded and conserved junk to avoid an AML program.
The proram is sort of ludicrous since a terrorist can trade in ill-gotten stolen coins for "legitamite" ones. Or a terrorist can take his cash booty and trade for MS65 Saints or other rare numismatic items which would be exempt. Then later sell those items for cash and avoid scrutiny.
To those on the forum who trade in PM's and generic $10's and $20's to the tune of over $100K per year, must maintain an AML program. This may not be so complicated if one only trades with say a few companies like Heritage, Blanchard or NGE. Your program could require that you only trade with these 3 firms (both purchases and sales), that you are the compliance officer, and then get an auditor to check it for content. Seems unlikely that you could be a target for terrorist laundering if you only deal with 3 of the most reputable firms in the country. Still, if one decides to safeguard their money from the ravages of FED induced inflation into PM's authorized by our constitution, you have to have an AML. While those that plop their $100K into stocks or other "good" investments, those that have a well earned distrust for paper assets are criminals
for considering PM's. The Patriot Act 2 AML provision is only the first step, the lack of M3 data from the FED is now the 2nd step, what will be next? All this looks like a concerted effort to destroy the PM market and prop up paper money further.
The fact that collectors and investors have to maintain such a program is ludicrous. Going rate for a canned program is $600 for
ICTA members and then $1000-$3000 for other firms who offer this.
My local dealer has signed up for the $600 program.
US Treasury AML link - bill #352
The above link has all you need to see. Nothing listed on how records are kept from buyers and sellers you deal with. Gee, if I buy $20 Saints from Heritage do I have to get Greg Rohan's fingerprints and SSN? Hmmmm?
roadrunner
0
Comments
So long as terrorists find ways to take advantage of our freedoms to hurt us, our government will react both politically and bureaucratically to stop them. It seems that more often than not this reaction is an overreaction, rather than a measured response. So here we go again.
Welcome to the New World Order.
I could blather about my feelings regarding this subject for hours, but I've got a party to go to.
THAT speaks volumes, doesn't it?
Check out my current listings: https://ebay.com/sch/khunt/m.html?_ipg=200&_sop=12&_rdc=1
It just looks like our uncle wants to keep better track of unreported & undocumented wealth.
I don't own anything like that so WHAT ME WORRY?
He must document if he doesn't reach the $50K mark for his own protection and he must document > $50K for the AML standards.
Under audit he needs to show that even if he gets 100 different bullion transactions per year at $500 each, all from small collectors, he has to document that he has an effective AML program.
Ironic that our own constitution says it is unlawful to have a coinage other than gold or silver. But here, if you transact $50K or more per year in US Eagles, you come under scrutiny for AML. You are following the constitution as written (our govt does not) but it is held against you. You must go through hoops that people transacting straight cash don't have to. Something tells me that if you took this to the SC that they could not find against you for following your rights under the constitution. Note that even a one time purchase over $50K for long term investment means that the following year you are required to have an AML program. Same thing when you sell it.
Wonder if you have $50K in US Eagles in a legal retirement plan (like Roth) and then go to sell them, if you still need to provide an AML program. Of course this is more than just anti-terrorism, as Uncle wants to know more of what you're doing, esp the un-American things like holding bullion.
For an additional $200 to the ICTA you can get the Terrorist's Bible for skirting the Patriot Act 2 bullion regs. Covers everything from buying 1804 dollars with your cash to PCGS regrades on your MS65 Saints. A well written primer (lol). The only ones left hanging out to dry are the honest dealers who have to comply. What's really funny is that the Treasury estimates only 20,000 people affected by this in the entire US and an average of one hour of paperwork required per person to meet annual AML program requirements.
roadrunner
1. I wonder how long before some wise ass bureaucrat 'wakes up' to the points you are making and calls for lists of all coin transactions over a certain amount be carried on the books...
2. Stamps are just as highly valued and even better to be used as a source of wealth and much easier to transport. Again I wonder how long before the same thing happens in the stamp business?
General comments:
IMO there has been an over reaction of the authorities all over the world in all aspects of trying to 'wage the war on terror'. This includes everything from the 'no flying lists' to the aspects of the act that you bring up. (Things that should have been years ago such as reinforcing doors in aircraft were never done.)
Here in Australia the government is going to pass some new laws to 'combat' the terror threat that IMO are unreasonable and not needed.
The basics in intelligence and criminal investigations have been ignored for years in this area and the failings of the intelligence/law enforcement entities not only in the USA, but other countries as well - have resulted in many stupid policies and plans being implemented. Many of these are being implemented to 'save' the people and play on their fears to the detriment of civil liberties. IMO there has been a waste of billions of dollars on idiotic programs in this arena while those that really need the funds to do basic intelligence and security work are ignored.
If you can not do the basics right the only other way is to limit your shortcomings is by trying to do an end around and IMO this what they are trying to do.
Terrorists have many ways of funding their activities and for the number of them that will try to use bullion dealers in the US IMO will/would have been miniscule......
(By the way I HAD a number of years in intelligence /law enforcement and am disgusted by the seemingly endless stupidities that I have seen over the years. Makes me wonder sometimes how ANYTHING ever gets done and done right!)
"section 352(c) of the act directs the secretary of the treasury to prescribe regulations for AML programs that are 'commensurate with the size, location and activities' of the financial institutions to which regulations apply"
Heritage or NGE or any other of the very large coin companies or auction houses would have to have a considerably more in-depth AML vs. a sole proprietorship that sets up at Sunday coin shows based on this section. Although i haven't seen anything from the secretary of the treasury as of yet saying what exactly would be required in an AML to be commensurate with my small business I have drawn up my own AML and will pursue more information as to weather it meets with the secretary's requirements. IF this quote holds true then a simple 1 page document could be all that is required for a small time coin dealer to be compliant with this regulation.
Andrew
Our eBay auctions - TRUE auctions: start at $0.01, no reserve, 30 day unconditional return privilege & free shipping!
<< <i>I wonder what jury would convict someone of the "crime" of not reporting bullion purchases/sales to the govt. >>
Now days many juries have "directed verdicts". If the juror refuses to play along he will go to jail.
<< <i>Now days many juries have "directed verdicts". If the juror refuses to play along he will go to jail. >>
Sounds like an interesting read--I should google that.
P.S. Just read up on that. If the courts aren't going to follow the Constitution anymore, why don't we just do away with it altogether rather than paying lip-service to it?
Roadrunner, did you read anything more on that issue?
Will we have to give our SSN to dealers like Heritage and Teletrade, and to the local "dealer" down the street as well, assuming the local coin shop dealer meets the definition of course?
RR
They would then of course report my suspicious behavior to the FED's as is required by the plan. Maybe I'm just mentally challenged and cannot figure out any numbers above 4 figures?
I was the one that mentioned SSN's in the first place but after reading the bill I don't see anything in there that would require it.
There already is a local law in CT (that few if any follow and few if any police depts enforce) to hold on to bullion merchandise for 30 days in the event it is stolen. Your name and I think address needs to be recoreded during the buying transaction. You also have to be licensed with the state to buy bullion in the state of CT. Very few dealers, other than brick and mortar shops actually comply.
Jade, it sounds like your idea is pretty sound. The govt already stated that only 1 hour of paperwork per year per person is required
to comply with the AML portion of this law. So it makes sense that a small business like yourself can draw up a plan to satisfy the law.
But unless you have transacted $50,000 in bullion in the past year there is no need to do it. But having a simple plan in any event is cheap insurance.
wonder what jury would convict someone of the "crime" of not reporting bullion purchases/sales to the govt.
The IRS and Treasury wouldn't have to do anything but hound your butt for a while to extract a pound of flesh. Lawyers cost. And the govt could care less what their lawyers cost because you and I pay for that. Few IRS cases ever get to the courts. I'm sure the majority that do are ruled in favor of the IRS. Look at the stupid Hager ACG case for heaven's sake. It's absurd but costs the plaintiffs plenty. What is silly is that the constitution demands silver and bullion as payment for debts, etc........yet the IRS will sue your ass for complying with the constitution. Amazing.
roadrunner
<< <i>The IRS and Treasury wouldn't have to do anything but hound your butt for a while to extract a pound of flesh. Lawyers cost. And the govt could care less what their lawyers cost because you and I pay for that. Few IRS cases ever get to the courts. I'm sure the majority that do are ruled in favor of the IRS. Look at the stupid Hager ACG case for heaven's sake. It's absurd but costs the plaintiffs plenty. What is silly is that the constitution demands silver and bullion as payment for debts, etc........yet the IRS will sue your ass for complying with the constitution. Amazing. >>
RR: good point. The post I was referring to mentioned a possible criminal penalty of five years in prison. Granted that the government's lawyering may be awesome while you may have a public defender, but the case would eventually still have to go to a jury. Of course, with this "directed verdict" thing, I suppose there really isn't much of a point in having juries anymore.
<< <i>
RR: good point. The post I was referring to mentioned a possible criminal penalty of five years in prison. Granted that the government's lawyering may be awesome while you may have a public defender, but the case would eventually still have to go to a jury. Of course, with this "directed verdict" thing, I suppose there really isn't much of a point in having juries anymore. >>
A directed verdict is hardly common but is used where the government claims that the average
man can't understand the law. Considering the quality of education, the growing complexity of
law, and the ability of more educated people to escape jury duty it is becoming increasingly com-
mon.
The government (any government) usually gets what laws passed and enforced that it wants.
U.S. Going to Track All Bullion Sales?
I read that previous link you just posted and I don't think it is required to report anything to the IRS. But I would agree that the dealer needs to keep a record of his transactions to show that he is in compliance. A $10,500 transaction in MS64 saints would not be equivalent to a $10,000 "cash" transaction as only about $5000 of the transaction is really bullion. Now if that were $20,000 in Saints then maybe that would qualify.
A Patriot Act 2 is more about setting up an anti-money laundering
program than reporting gold transactions.
A dealer who did not make $50K in bullion sales the previous year is exempt from from PA2 during the current year. He would need to show records if asked to prove that I suppose. And if proven, I don't see how they could look at his current year records. But say he reaches $50K the next year then he would fall into it. A dealer who reached $50K one year, and then less than $50K the next, would fall out of after the 2nd year. Very convoluted.
In re-reading other articles I may have been wrong in stating that the sum of one's bullion sales and purchases needs to be > $50K.
It appears that only purchases need to be > $50K.
roadrunner
It is clear that even transactions significantly below $10,000 will have to be reported if it is included as part of a series of successive transactions.
Here it is below:
<< <i>Section 103.140(c) sets forth the minimum requirements of a dealer’s money
laundering program. Section 103.140(c)(1) requires the anti-money laundering program to
incorporate policies, procedures, and internal controls based upon the dealer’s assessment
of the money laundering and terrorist financing risks associated with its line(s) of
business. Policies, procedures, and internal controls must also be reasonably designed to
ensure compliance with BSA requirements. The only BSA regulatory requirement
currently applicable to a dealer is the obligation to report on Form 8300 the receipt of
cash or certain non-cash instruments totaling more than $10,000 in one transaction or two
or more related transactions.6 To assure reasonable compliance, the program should be
reasonably designed to detect and report not only transactions required to be reported on
Form 8300, but also activity designed to evade this reporting requirement. Such activity,
commonly known as “structuring,” may involve payments of more than $10,000 with
multiple money orders, travelers’ checks, or cashiers’ checks or other bank checks, each
with a face amount of less than $10,000. Such methods of payment may be indicative of
money laundering, particularly when the payment instruments were obtained from
different sources or the payments were made at different times on the same day or were
made on consecutive days or close in time. Should dealers become subject to additional
requirements, their compliance programs would have to be updated to include appropriate
policies, procedures, training, and testing functions relating to such requirements.
Section 103.140(c)(1)(i) provides that, for purposes of making the risk assessment
required under section 103.140(c)(1), a dealer must consider all relevant factors,
including those listed in the rule. First, the dealer must assess the money laundering and
terrorist financing risks associated with its products, customers, suppliers, distribution
channels, and geographic locations. In addition, a dealer must take into consideration the
extent to which the dealer engages in transactions other than with established customers
or sources of supply. Finally, a dealer must analyze the extent to which it engages in
transactions for which payment or account reconciliation is routed to or from accounts
general partnership. >>
So 4 $3,000 bullion transactions or gold Saints bought or sold in successive days OR CLOSE IN TIME is greater than or equal to the $10,000 required reporting under the BSA rules and now under Section 103.140(c).
A number of years ago the ICTA, after they and others had many meetings with the IRS put out a packet that outlines the guidelines for both filing 8300 cash reporting and specific guidelines for issuing 1099 form at the end of the year for bullion sales. On bullion sales there are specific rules which apply to certain amounts of each type of bullion type that trigger a 1099.To obtain this information please contact ICTA as alot of money went into developing this, it's not right to post the info here. I DO NOT work for ICTA.
Now in reading the new regulation and ICTA"s new paperwork the only thing that is completely clear is that the definition of bullion seems to have been changed to mean anything that derives 50% or more of it's value from the metal content of the item, known also as a "covered item"
After reading the patriot act section and ICTA's release I do not see anything what so ever that changes the 8300 reporting to include low grade St's or Libs and ICTA has informed me that the 8300 reporting rules have not changed despite all of the hype. That doesn't mean they won't change it just hasn't as of now.All it says is that if you buy / sell $50,000 or more in "COVERED ITEMS" with the public then you must have a plan in place.
I recieved a letter from a customer from a one Lawrence Patterson, a newsletter writer of some sort warning his customers about the impending reporting requirement changes. His pitch is to sell all of the low grade 20's and upgrade them into true numismatics beacuse the governmnet was fixing to take them, report them etc. To my surprise at the end the final advice was to contact xyz company ( who happens to be a coin world advertiser) for assistance. Ya think there is a profit motive behind all the hype?
If someone can please point out any specific language that changes the current requirements or scope of 1099 or 8300 reporting requirements please post them. As far as I can tell by reading all of this stuff is that a plan is required if you do x amount of business in covered items, no additional items are listed for dealer reporting and it doesn't seem like anything new has been added to the cash instrument list.
If you have specific language we may have missed by all means please post it as it would be very helpful to all.
I did not read anything in the regs that exempts coin "wholesalers," of which there are thousands. The reg on my earlier link specifically lists wholesalers since they can launder money just as good as anyone else if they wanted. If a wholesaler is moving $50K in bullion from one dealer to the next then he is not exempt. Only exemption is from retailers who buy from dealers and sell to the public. There are many smaller coin dealers doing business mainly in gold coins who do business mainly as wholesalers. I see no exemption for them as well as investors who buy $50K or more per year in bullion. If there is a diff interpretation please show me the verbage that leads you to that conclusion.
Oreville, what you stated has been in effect long before this PA2 bill came about. But the question is about how you record and process the transactions. Looks like though I have to file a form 8300 if I'm buying say $50K in US Eagle gold from Heritage or any other coin firm. Whether I should also report the purchase of $100K of Saints from Heritage is another question but seems to be the interpretation from many.
I would agree about the .500 gold fineness standard in the reg.
It appears to address gold bullion only and not coins.
The ICTA has inferred that this means coins deriving 50% or more of their value from bullion. Others have stated the same thing if you search the web. One would need a Treasury official's opinion on that one. But the intent as written would not seem to apply to higher grade $20's. How much money laundering if any really occurs with MS63 and higher $20 gold pieces!
Cashier's checks are considered "money" but I cannot recall if I read that in the old Bank Security Act (BSA) or if now appears here for the first time as part of the AML bill. A little short on time right now to reread it all.
Basically this new bill requires you to be on the alert for AML schemes. That's the brunt of it. $50K is the line in the sand. The bill is very specific towards bullion dealers and jewelers.
roadrunner
<< <i> Such activity,commonly known as “structuring,” may involve payments of more than $10,000 with multiple money orders, travelers’ checks, or cashiers’ checks or other bank checks, each with a face amount of less than $10,000. Such methods of payment may be indicative of money laundering, >>
But more likely simply means that someone is trying to protect his privacy. How DARE he!
Are numismatic coins really bullion?
If one were to read the bill literally, any gold coin > .500 fineness
(ie. all US gold coins ever issued) would qualify.
roadrunner
6024 N. 9th Ave #5
Pensacola, FL 32504
HTTP://WWW.AACoinCo.Com
I used to sell 40% clad to some very secretive buyers. Also UPS will ship 40% bags. Now all you have to do is have a couple acres to STORE the stuff.
What we have here are two separate requirements:
1) is the older BSA/IRS requirement regarding the $10,000 cash reporting on form 8300. That has not changed.
2) Is the newer Patriot Act rules which refer to the BSA requirements and has now effectively doubled up on the rules with further penetration into bullion, coin bullion, etc.
<< <i>First, dealers have always been required to file cash reports after certain conditions were met whether the customer was buying bullion, low grade 20.00's or rare coins. >>
CORRECT. I HOPE I HAD MADE THIS PREVIOUSLY CLEAR ON THIS. ACTUALLY THE CASH REPORTS HAVE BEEN REQUIRED FOR ABOUT 10-15 YEARS OR SO (I FORGET EXACTLY HOW LONG AGO).
<< <i>Now in reading the new regulation and ICTA"s new paperwork the only thing that is completely clear is that the definition of bullion seems to have been changed to mean anything that derives 50% or more of it's value from the metal content of the item, known also as a "covered item" >>
AGAIN, CORRECT. EXCEPT THAT THE PATRIOT ACT SECTION MADE IT MORE EXPLICITLY CLEAR THAT TRANSACTIONS OF LESS THAN $10,000 WHEN DONE REPETITIVELY IN A PERIOD OF "CLOSE IN TIME" TOTALLING MORE THAN $10,000 IS ALSO SUBJECT TO THE REPORTING REQUIREMENTS.
THE KEY POINT I AM MAKING HERE IS THAT FOR THE VERY FIRST TIME, THE BSA/IRS FORM 8300 REGULATIONS ARE NOW BEING USED AS PART OF THE PATRIOT ACT (AS A DUPLICATE REQUIREMENT UNDER ANOTHER STATUTE) FOR A DIFFERENT PURPOSE. THE PENALTIES FOR FAILURE TO COMPLY ARE DIFFERENT UNDER EACH STATUTE!!!!
<< <i>If someone can please point out any specific language that changes the current requirements or scope of 1099 or 8300 reporting requirements please post them. As far as I can tell by reading all of this stuff is that a plan is required if you do x amount of business in covered items, no additional items are listed for dealer reporting and it doesn't seem like anything new has been added to the cash instrument list. >>
AGREED, NO CHANGE TO THE IRS FORM 1099 OR FORM 8300 REPORTING REQUIREMENTS IN THEMSELVES. I HOPE THAT I HAVE NOT MADE ANYONE THINK OTHERWISE. HOWEVER, THE DEFINITION OF CASH APPEARS TO BE BEEN WIDENED TO INCLUDE BULLION AND COIN BULLION.
EXAMPLE; NO CHANGE WHEN SOME ONE PAYS WITH $20,000 CASH TO BUY $5,000 FACE VALUE 90% US SILVER COINS. THAT IS STILL A CASH PAYMENT SUBJECT TO THE REPORTING OF FORM 8300 AS BEFORE. THE PAYMENT OF $20,000 BY CHECK FOR THE SAME $5,000 IN FACE VALUE OF US 90% SILVER COINS WAS NOT REPORTABLE PREVIOUSLY. HOWEVER, STARTING IN 2006, SUCH SAME $20,000 CHECK PAYMENT FOR THE $5,000 IN FACE VALUE OF 90% US SILVER COINS COULD VERY WELL BE SUBJECT TO THE PATRIOT ACT REQUIREMENTS BUT NOT UNDER THE OLD AND STILL CURRENT BSA/IRS FORM 8300 REQUIREMENTS.
WHY IS THIS SO? APPARENTLY, THERE IS A CONCERTED EFFORT BY THE WRITERS OF THE PATRIOT ACT TO INCLUDE THE "FAIR MARKET VALUE" OF US BULLION COINS IN THE DEFINITION OF CASH AS MUCH AS POSSIBLE. BASED ON THIS SCENARIO, EVEN A TRADE OF US GOLD COINS FOR OTHER US GOLD COINS OR SILVER COINS MAY BE SEEN AND DEFINED AS A CASH TRANSACTION!!! I SUSPECT THAT THE 50% RATIO OF BULLION VALUATION OF THE COINS FULL VALUE AS MENTIONED BEFORE WAS SOME KIND OF A COMPROMISE BUT CANNOT SUBSTANTIATE THIS. IT IS BASED ON MY OPINION ONLY..
THIS IS A HUGE CHANGE!!!!!
<< <i>Cashier's checks are considered "money" but I cannot recall if I read that in the old Bank Security Act (BSA) or if now appears here for the first time as part of the AML bill. A little short on time right now to reread it all. >>
It was in the old BSA. Cashiers/tellers/bank checks are considered alternate forms of cash.
By the way an experienced poster asked me if bank wires were considered cash or not. No, bank wires are considered as a check/no cash payment. The key point to defining NON CASH TRANSACTIONS is whether the funds go from checking or savings acount DIRECTLY to another checking or savings account or to make a payment. If the recipient cashes the check of over $10,000 when it was made payable to him raises an interesting question of whether the recipient now has to file a form 8300 on himself!?!?!? I do not think the maker of the check is required to verify what the recipent does after payment as long as the check was made payable to the recipient (as long as the receipient operated under his own name only = if operates under a different business name but asks for the check to be made to himself then the maker of the check has a problem!!!)
Wondercoin
...
Well Mr. Washington, Jefferson and Ben, you all tried, but I guess you’ve met your match!
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<< <i>I wonder what jury would convict someone of the "crime" of not reporting bullion purchases/sales to the govt. >>
That's a good point however it would cost the "alleged law breaker" tens of thousands of dollars in legal fees alone just to get to that jury to find out.
Coin's for sale/trade.
Tom Pilitowski
US Rare Coin Investments
800-624-1870