In 2018, a US gold refinery pled guilty to failing to maintain an adequate anti-money laundering program. According to the investigation, between August 2012 and November 2016, the company purchased and refined billions of dollars’ worth of gold sourced from countries worldwide. The company operated transnationally in regions such as Latin America, the Caribbean, and Europe. The international gold trade is at high risk of money laundering linked to illegal mining, narcotics, or other criminal activities. Given this high risk, US federal law requires any precious metal dealers to have anti-money laundering programmes in place. The company was subject to this law and aware of its obligations; however, it failed to develop, implement or maintain an anti-money laundering program. The evidence showed that the company had accepted gold from entities without requesting identification or adequate identification and accepted gold from suppliers and countries whose records indicated a high likelihood of gold smuggling and front companies. The company accepted gold from sources where open-source information suggested it was criminally derived, and failed to request, obtain or adequately preserve chat records between gold suppliers and the company’s agents. The company forfeited $15,000,000 to the state, agreed to develop an adequate compliance program and was subjected to a 5-year probation where the company was forbidden to purchase metals from outside the United States.