US Government enters into non-prosecution agreement with gold refinery

Miami-based, gold refinery Republic Metals Corporation (“RMC”) executed a non-prosecution agreement with the United States Attorney’s Office for the Southern District of Florida after cooperating in an investigation focusing on money laundering and violations of the Bank Secrecy Act in the gold importation and refining industry.  Under the terms of the agreement, RMC agreed to continue cooperating in the ongoing investigation into the gold industry, as well as to make improvements in its anti-money laundering and compliance programs.  RMC received full credit for voluntarily cooperating with the investigation, including the production of over 100,000 emails and messages, and the expenditure of over $1 million on a new compliance team and sourcing model (called Peace of Mined) to eliminate metal aggregators from its supply chain.  The company has also enhanced its anti-money laundering compliance program, and severed relationships with potentially suspicious suppliers before becoming aware of the government’s investigation.  The agreement does not impose an independent compliance monitor, and the government will not levy a fine against RMC. 

The U.S. Attorney’s Office in South Florida has been investigating Miami’s gold trade in an effort to combat the trade of illegally mined gold from Latin America by drug traffickers.  As part of the agreement, Republic agreed to stop business with aggregators, which are businesses that collect gold from small mines and then “aggregate” the gold into bulk sales to large buyers.  This makes it difficult to trace whether the gold was mined legally.
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