NACS has access to an array of highly experienced, retired federal agents providing a wide range of services, including electronic monitoring and surveillance. We have provided training and consulting services for many companies in numerous industries, financial professionals, law-enforcement and government agencies. We have developed and written hundreds ofin addition to conducting AML independent (testing) audits/reviews of AML Programs around the United States.
Raymond (Ray) Gregson, Jr., retired from the IRS, Criminal Investigation (CI) as a Senior Special Agent and Money Laundering Expert on December 31, 2004, after more than 28 years of law-enforcement service.
From October 2000 until his retirement, Ray was also the Public Information Officer, dealing with the press on all levels regarding criminal cases and other IRS-CI issues in the New Orleans Field Office.
Ray conducted criminal income-tax investigations virtually throughout his career, but from about 1982 until his retirement, his criminal cases and other assignments focused almost exclusively on narcotics and money-laundering investigations. Ray was responsible for virtually all money-laundering training and was consulted on virtually every money-laundering case in the New Orleans Field Office (Louisiana and Mississippi and for part of Ray’s career, Alabama was also part of the New Orleans Field Office) and by many special agents throughout the United States on complex money-laundering cases. Ray was considered the point of expertise and conducted money-laundering (AML/BSA) training for New Orleans Field Office special agents, for local, state and federal law enforcement, including the U.S. Attorney’s offices in Louisiana, Mississippi, and Alabama and for most of the financial institutions throughout the field-office area. Since 1982, Ray has conducted more than about 800 AML/BSA training classes for financial institutions, casinos, automobile dealerships, precious-metals dealers and other businesses and organizations throughout the United States, even marijuana labs. Ray was also an instructor at money laundering classes and conferences on more than 70 occasions since 1982, including three international money-laundering classes (in St. Petersburg, Russia; and Tallinn, Estonia). Also, since 1996 Ray has been qualified as a money laundering and cash reporting expert in Federal Court on at least four occasions and was requested many more times, but the investigative targets in those cases pled guilty before the beginning of or during the criminal trial.
Since his retirement in December 2004, Ray has been consulting with and training numerous industries, including some of the same industries he worked with while a special agent with IRS-CI. Although the vast majority of his consulting and training is with the precious-metals industry, he continues to conduct training and AML/BSA reviews/audits for other industries, including MSBs (money service businesses). He also continues to be consulted as an expert by current and retired special agents of IRS-CI. Some of these retired IRS-CI employees now work as contract employees for other federal law-enforcement agencies, including the FBI and the U.S. Attorney’s Office.
Phil Hull retired from the IRS, Criminal Investigation (CI) as a Supervisory Special Agent in January 2014, after 27 years of federal law-enforcement service.
During his IRS-CI career, Phil successfully completed more than 200 criminal financial investigations. His case load included numerous tax-related and other financial-fraud cases, many of them having a domestic and/or international money-laundering component. He was successful in the prosecution of virtually every case he investigated.
Phil also has extensive experience with the requirements of the Bank Secrecy Act (BSA). He was the lead case agent for the federal grand jury investigation of AmSouth Bank in 2004, which involved BSA reporting requirements, including failure to file Suspicious Activity Reports (SARs) in a timely, complete, and accurate manner. The AmSouth case resulted in the bank’s agreeing to pay fines and penalties in the amount of $50 million.
In addition, Phil was instrumental in the start-ups of several financial-crime task forces, including a one dedicated primarily to the mortgage-fraud epidemic. More recently, he spearheaded an identity-theft task force. He received numerous awards during his career, including nationwide selection as IRS-CI Special Agent of the Year.
JM BULLION, INC.
It is a pleasure working with Ray Gregson and his company, National Association for Compliance & Security, over the past three years. During this time period, Mr. Gregson has been extremely helpful in keeping JM Bullion, Inc. educated and AML Compliant. Once a year, Mr. Gregson travels to JM Bullion’s headquarters in Dallas, Texas, to conduct training and answer any questions from JM Bullion’s ENTIRE team regarding the AML rules and regulations. It is important to note that not only does AML training affect an Accounting/Compliance team, but it also affects all customer-facing departments. After educating our team, Mr. Gregson reviews an AML quiz that all employees are required to take annually, and reviews every question until the correct answer is clearly understood. Mr. Gregson not only instructs on AML rules & regulations and cash reporting requirements, he also provides real life examples of money laundering issues he has experienced in the past in our industry. During his annual visit, Mr. Gregson performs an independent audit by reviewing transactions over the past year that could have potentially lead to the filing of a Form 8300. He also reviews all Forms 8300’s that JM Bullion has filed over the past year and confirms that we have followed all of the necessary steps. Upon completion of the audit. Mr. Gregson supplies JM Bullion with an AML Audit Report package, that completely satisfies all constituencies to which JM Bullion reports its annual AML audit findings. Mr. Gregson also makes himself available throughout the year, ensuring JM Bullion is continuously up-to date and AML compliant.
Mr. Gregson is extremely knowledgeable and it is clear he been heavily involved with AML practices for quite some time. He is always available and willing to provide insight on transactional situations for which JM Bullion seeks guidance. As a leading online retailer of precious metals, it is crucial that JM Bullion receives the best guidance and remains compliant with all AML rules & regulations. With Mr. Gregson, JM Bullion is confident that we have both. JM Bullion has been more than happy with all of the services Mr. Gregson provides through his company and highly recommends Mr. Gregson to any company seeking the best AML guidance and independent audit services.
Director of Finance
JM Bullion, Inc.
AMERICAN FEDERAL RARE COIN & BULLION
I had the pleasure of meeting Ray four years ago when he provided training for the entire staff at American Federal, tested our safeguards and controls, and audited our AML Program to ensure we were compliant, with regard to the AML regulations and the USA PATRIOT Act. Not only was Ray thorough in his audit, but incredibly knowledgeable on the rules and regulations governed by IRS and FinCEN. He provided extensive insight to us as a precious metals dealer, as he continuously does on a regular basis. Periodically throughout the year, I receive an email from Ray keeping me up to date of new changes to the guidelines as well as reminders of things I must do to stay compliant.
Interesting enough, when I first met Ray he told me that many precious metal dealers did not utilize his service, which he couldn’t understand because banks place very high regard to his reports and his audits could help prevent a company from having their bank account closed for no reason at all. I was a bit reluctant by this, thinking it was a mere “sales pitch”, but soon was told by my bank that they were in fact closing many coin dealer accounts, but we were safe because we provided them with our “AML Plan” and “AML Independent audit report” on an annual basis.
Additionally, I feel fortunate to work with Ray because I continuously find myself emailing him with questions or concerns I might have, which arise throughout the year. I have the assurance that I am receiving the best and correct information. He is always quick to respond and thoroughly. I highly recommend Ray Gregson as a business partner to help remain compliant with the AML regulations and the USA PATRIOT Act
Michele Sapero, CPA, COO
American Federal Rare Coin & Bullion
BARRY STUPPLER & CO., INC.
Ray Gregson has been conducting our AML independent audit for the past eight years. We are fortunate to have him train myself and my staff on the issues & importance of the AML regulations and cash reporting. His yearly independent audit of our records and AML Program has been extremely valuable. Ray’s knowledge of and experience with the AML regulations is second to none and we are always prepared and compliant. Ray’s professional approach gives me the confidence that my company is properly trained and ready for any situation. I would wholeheartedly recommend Ray to anyone who is in need of an AML Program and compliance with the AML regulations.
Stuppler & Company
AMERICAN PAPER MONEY & COIN
Lois and I attended Ray Gregson’s seminar at the FUN Show and we can assure you it was well worth the time and travel expense to do so. We can also assure you that the fee for his services, knowledge and expertise is well worth the investment. During the seminar we immediately recognized the true value of the service Ray offers. Coin dealers who don’t understand AML compliance may lose money by refusing to conduct transactions that are perfectly acceptable. They will also risk the serious consequences for conducting transactions that fail to comply with the AML regulations. This is a no-brainer. If you are trading in bullion, give yourself the peace of mind of working with a real professional. You’ll be glad you did.
Stephen L. Goldsmith
American Paper Money & Coin, LLC
Ray has conducted our annual anti-money laundering (AML) services (independent audit and training) for my business since the regulations became effective. He supplies us a with an audit report that is professionally written and details his findings, comments, and any corrective measures. He has also trained our entire staff each year. Ray also came in the day prior to an IRS exam to be certain that our records were in order. The IRS auditor stated that our records were in perfect order and the AML program was as good as she has seen.
Ray is also available to us 24/7 for answering critical questions concerning transactions being conducted. If he does not answer his cell phone, he gets back in touch with us within 1 hour. Although I know Ray has other clients, he makes me feel as though Lear Capital is his only client.
Ray is extremely professional and competent in the services he performs. I would recommend him to anyone and any industry that is required to comply with the AML Regulations and wants to be in full compliance.
Lear Capital, Inc.
If you care about your business and your future, then you know how important it is to do things right. And after all, I am a coin dealer, not an accountant or attorney, and it is my job to buy and sell coins. That said, there are laws and rules that regulate my behavior and I need a professional to protect my interests and to make sure I do things right.
That is why when the government passed the USA PATRIOT Act and included provisions for the coin industry, I immediately got in touch with Ray Gregson. We discussed my business and he proceeded to develop an AML Program just for HCC, Inc. A few months after the plan was completed, Ray made a visit to my company in Toledo, Ohio, to conduct an independent review of my procedures as far as my plan and business activities were concerned and to put on a training session for all of my employees.
This has been an annual event to keep HCC in line with regulations related to the USA PATRIOT Act, and it affords me a wonderful peace of mind. I would strongly recommend Ray to anyone who has to deal with governmental regulations, as his experience is invaluable. Please feel free to call me if you have any questions.
Howard C. Cook, Jr., President
SILVER TOWNE, L.P.
As a company that has had prior experience regarding complications that can arise if one does not comply with the rules and regulations of filing specific forms, when the USA PATRIOT Act and then the final rule concerning the AML Requirements for our industry were established, we were very concerned and wanted to make sure we took appropriate measures to become compliant. Mr. Ray Gregson has greatly helped Silver Towne comply with all of these regulations. Ray first offered so much insight to our company when he spoke at the FUN Show in Orlando, Florida. I attended the show along with David Hendrickson, General Partner, and was very impressed with Ray’s knowledge of the newly enacted AML regulations and precious-metals background. David and I decided we would have Ray create an AML Program specifically designed for our company.
Ray has been great to develop an AML Program for our company and has been helping Silver Towne with compliance issues for three years now. He is available for questions or concerns during most hours of the day. The compliance officer or any other employee can e-mail or call him and can get an answer within a very short time period. I recently had to call Ray with a situation that needed immediate attention and his expertise on how to handle it. When I called him I was not surprised that he answered the phone right away, but was surprised when I found out that he was in the country of Poland. I thought that was extraordinary service to us.
Recently, when the IRS performed an 8300 compliance audit of our company, Ray came to our company the day before to make sure we had all the appropriate reports and forms available for the IRS. Ray stayed at Silver Towne until the audit was finished and there were no problems or violations found, thanks to him.
Ray is very enjoyable to work with. He is very friendly and is very open to any questions we might have. He devotes so much to our company, that it seems as though we are the only business that matters. I would recommend Ray to any precious-metals dealer or other establishment with pleasure and confidence. If you should have any questions concerning Ray or the services he performs for Silver Towne, please do not hesitate to call me or our compliance officer, Todd Huth.
David Hendrickson, General Partner
Silver Towne L.P.
765-584-7481 or 1246
SILVER BAY COIN & BULLION
We began business in the middle of 2010 and did not believe we were required to comply with the AML Regulations or have an AML Program. A year later…we received a short, curt notice from our bank that all of our accounts would be closed in 60 days if we did not produce an AML Plan (Policies and Procedures manual) and an independent audit report. Our deposits, which increased with the rise of silver & gold prices as well as an increase in business, had raised red flags. Fearing that we may be conducting business with “undesirables,” they would not do business with us without an AML Program. PANIC!!
Ray was recommended by another dealer who is very happy with the services he receives. Although extremely busy, once Ray became aware of the extremely short time frame we had been given, he worked during his vacation to quickly and efficiently provide us with an AML Plan, the required training, and an independent audit report… WOW!! With Ray’s background, he also pointed out some accounting procedures that will help us in the event of an IRS compliance exam and also during an independent review… Needless to say, Ray’s recommendations were quickly implemented!
Ray is very friendly and quick to answer any questions or concerns. He also showed extreme patience with our lack of knowledge regarding these issues and other governmental regulations. We would, with great confidence, whole heartedly recommend Ray to anyone who requires assistance with AML or cash-reporting issues.
Silver Bay Coin & Bullion