Criminals distort the declared or appraised values of jewelry, often inflating or underreporting prices to launder illicit funds. With high portability, easy cross-border movement, and subjective valuations, jewelry can be resold multiple times, complicating financial oversight and obscuring money trails. By repeatedly changing ownership or adjusting declared worth, launderers add complexity to the layering process. In some instances, stolen pieces are sold multiple times in different jurisdictions without proper verification, aided by appraisers who may not question irregularities or missing documentation, such as a valid Kimberley Process Certificate. Common red flags include eagerness to sell or purchase at suspicious prices, willingness to accept below-market or highly inflated valuations, and repeatedly transferring ownership among related entities. Because of jewelry’s inherently high value and ease of transport, this technique remains a preferred method for layering illicit funds through manipulated appraisals and sales cycles.
Jewelry Valuation Manipulation
Jewelry Valuation Exploitation
Tactics
Criminals exploit the subjective and portable nature of jewelry to repeatedly trade and resell items across various jurisdictions, creating opaque transaction chains that distance illicit funds from their criminal origins. By inflating or underreporting values during each sale, this technique primarily supports layering to obscure the original source of funds.
Risks
Criminals exploit the inherent subjectivity and high portability of jewelry by repeatedly inflating or underreporting its value. Since valuations can vary widely and are often not rigorously verified, adversaries can layer funds through multiple resales. This is the central vulnerability that enables distorted price declarations to disguise illicit proceeds.
The technique deliberately involves cross-border transactions, exploiting weak or inconsistent oversight and documentation requirements (e.g., missing Kimberley Process Certificates) across multiple jurisdictions. This enables criminals to shuttle jewelry between regions with inadequate AML enforcement, further obscuring ownership and declared values.
Indicators
Frequent purchase and resale of identical jewelry pieces within short periods at significantly varying declared values.
Customer repeatedly revises declared jewelry appraisals or modifies insurance coverage amounts without providing credible supporting documentation.
Entity located in or frequently transferring jewelry through jurisdictions with limited valuation oversight or verification requirements.
Multiple related entities or individuals transferring ownership of the same jewelry piece among themselves, each time reporting sharply altered valuations.
Repeated international transfers or shipments of jewelry lacking required documentation (e.g., missing Kimberley Process certificates) or incomplete appraisals, especially for diamonds.
Data Sources
- Documents import and export declarations, shipping routes, and required certifications for jewelry.
- Comparing declared values to actual market prices and verifying missing or incomplete certificates (e.g., Kimberley Process) helps detect suspicious under- or over-valuation.
- Consolidates risk profiles of jurisdictions lacking adequate valuation oversight.
- Highlights frequent jewelry transactions routed through high-risk regions, aiding in the detection of potential layering and value manipulation schemes.
Provides reference prices, historical valuations, and price indices for precious metals and gemstones. By comparing declared jewelry worth to credible market benchmarks, financial institutions can detect artificially inflated or deflated valuations indicative of money laundering schemes.
- Provides comprehensive records of purchases, sales, and related financial transactions for jewelry.
- By identifying repeat transactions of the same piece at inconsistent valuations, financial institutions can detect possible layering attempts or artificial price manipulation.
- Includes bills of lading, invoices, and certificates of origin relevant to jewelry shipments.
- Missing or inconsistent documentation for high-value items can signal manipulated valuations used to conceal illicit funds or evade regulations.
- Contains verified customer details, asset declarations, and insurance coverage data.
- By examining ongoing updates to jewelry valuations or appraisals, analysts can detect inconsistencies or repeated changes lacking credible justification, revealing potential laundering.
- Tracks ownership changes and recorded valuations for high-value assets, including jewelry.
- Identifies abnormal fluctuations in appraised values when the same item is transferred multiple times, indicating potential manipulation for layering or illicit value movement.
- Presents formal ownership data for legal entities and beneficial owners.
- Exposes relationships among individuals or entities repeatedly transferring the same jewelry piece, helping uncover collusive activity aimed at manipulating valuations.
Mitigations
Apply advanced scrutiny to high-value or suspicious jewelry transactions by verifying appraiser credentials, demanding additional supporting documents (e.g., Kimberley Process Certificates), and comparing declared prices to reference price indexes from recognized gemological sources. Confirm beneficial ownership or third-party involvement when repeated unusual valuations occur, mitigating the risk of manipulated jewelry appraisals.
Collect and verify documentation evidencing a legitimate business purpose, market-consistent valuations, and proper ownership for jewelry transactions at onboarding and during periodic reviews. Cross-check declared values against recognized gemological references or industry price benchmarks to detect over- or under-reported valuations.
Implement specialized monitoring scenarios focusing on jewelry transactions that exhibit repeated short-interval purchases or sales with drastically altered declared values, frequent cross-border movements, or incomplete documentation. Investigate abrupt price fluctuations or ownership transfers among related parties or in high-risk jurisdictions to uncover potential manipulation in the layering process.
Assess and continuously monitor the AML compliance of external jewelry appraisers, brokers, or shipping agents. Incorporate explicit AML clauses into contracts or service-level agreements, requiring accurate appraisals, verified shipping records, and complete documentation. This reduces the risk that unvetted third parties facilitate manipulations of jewelry valuations.
Use escrow solutions for high-value jewelry trades to confirm authenticity, valuation documentation, and lawful provenance before releasing funds. This measure prevents launderers from finalizing transactions based on fabricated or grossly inflated/deflated jewelry prices by ensuring discrepancies are resolved or investigated in advance.
Consult public gemological databases, stolen jewelry registries, and industry watchlists to verify the authenticity and typical price ranges for jewelry pieces. Validate the identity and reputation of appraisers or dealers through external sources, ensuring that excessively inflated or undervalued prices are challenged and escalated for further review.
- Restrict or delay high-value jewelry transactions if the customer cannot provide credible appraisals or documentation supporting declared valuations.
- Deny or freeze services when repeated resale patterns show drastically changed values or when there is evidence of deliberate misrepresentation.
- Ensure that unresolved issues are investigated before allowing transaction completion.
Review and cross-check shipping documents, insurance policies, and commercial invoices for jewelry imports or exports, particularly if the declared valuation is inconsistent with standard market references or changes drastically between transactions. Identify misinvoicing patterns or repeated re-exports through multiple jurisdictions lacking valuation oversight.
Instruments
- Criminals inflate or understate jewelry appraisals to insert or extract illicit funds from transactions under misleading valuations.
- The subjective nature of jewelry pricing—relying on appraisers who may not verify authenticity or origin—allows repeated resale of the same item at widely varying prices.
- High portability and ease of cross-border shipment facilitate layering: criminals can move pieces across jurisdictions, obscuring money trails and sidestepping stricter oversight.
- Missing or falsified documentation, such as improperly obtained or absent Kimberley Process Certificates for diamond jewelry, further hinders traceability and weakens verification of actual value.
- Criminals resell raw or lightly processed gemstones (e.g., diamonds) or precious metals at manipulated values to disguise the true amount of illicit proceeds.
- Subjective or inconsistent appraisals, particularly for rough diamonds lacking a valid Kimberley Process Certificate, create opportunities for repeated layering across multiple jurisdictions.
- By avoiding standardized market checks or proper documentation, launderers shift and re-price these assets to obscure ownership chains and complicate audit trails.
Service & Products
- High-value or antique jewelry can be sold via auction houses where subjective appraisals permit significant price manipulation.
- Repeat sales with altered valuations create layers of transactions, muddling ownership and audit trails.
- Criminals exploit cross-border shipping of jewelry with falsified or missing documentation—such as absent Kimberley Process Certificates—obscuring illicit origins.
- By moving pieces through multiple jurisdictions and forwarding agents, they complicate tracing and enable repeated revaluation or resale.
- Criminals can repeatedly pawn and redeem jewelry at manipulated valuations, laundering proceeds by inflating or underreporting their worth.
- Minimal specialized valuation checks create opportunities to introduce illicit funds into the financial system under seemingly legitimate transactions.
- Illicit actors convert jewelry into cash at fictional or inflated values, disguising the true origins and values of the assets.
- Limited record-keeping and oversight let criminals repeatedly exchange or resell pieces with falsified appraisals, facilitating layering.
Actors
Pawnshop operators can repeatedly accept jewelry at inconsistent valuations and grant or settle loans without thorough appraisals. This practice allows criminals to introduce illicit funds incrementally and complicates a financial institution’s due diligence when these transactions appear legitimate on the surface.
Illicit operators acquire or handle jewelry with distorted valuations to launder proceeds. They repeatedly buy, sell, or transfer pieces across jurisdictions using inflated or underreported prices, creating complex transaction chains that hinder a financial institution's ability to track ownership, detect unusual pricing, or identify the true source of funds.
Antique or high-value jewelry may be traded through auction houses or galleries, where subjective appraisals allow for significant price manipulation. Repeated resale at varying declared values obscures the transaction trail, impeding financial institutions' efforts to verify beneficial ownership or determine accurate worth.
By shipping jewelry across borders with missing or falsified documentation—such as absent Kimberley Process Certificates—these companies are often exploited, sometimes unwittingly, to move items through multiple jurisdictions. The resulting lack of transparent paperwork complicates financial institutions' ability to track the true origin, value, or ownership of the assets.
Such dealers may knowingly or unknowingly accept jewelry at suspiciously high or low declared values. By not consistently verifying market prices or ownership documentation, they facilitate layering and make it challenging for financial institutions to reconcile transaction amounts with true appraised values.
References
FATF (Financial Action Task Force). (2003, February 14). Report on money laundering typologies 2002-2003. FATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Moneylaunderingtypologies2002-2003.html
The Anti-Money Laundering Steering Group. (2019). Cayman Islands Money Laundering Typologies & Trends. https://cnslibrary.com/wp-content/uploads/Money-Laundering-Typologies-and-Trends-Sept-2019.pdf