Federal Investigation of My Jewelry Store
The Investigation Started Before You Knew
Welcome to Spodek Law Group. Our goal is to give you the reality of federal jewelry store investigations - not the sanitized version other lawyers present, not the Hollywood fiction, but the actual truth about what happens when federal agents start looking at your business.
Here is the thing nobody tells jewelry store owners: by the time federal agents show up at your door, they have probably been investigating you for twelve to twenty-four months. They have already subpoenaed your bank records. They have already interviewed your suppliers. They have already pulled every Form 8300 you filed - and every one you should have filed but did not. The visit you thought was the beginning? It is closer to the end.
This is the fundamental asymmetry that destroys jewelry business owners who try to handle things themselves. The government has been building their case for a year or more while you have been running your store, completely unaware. They know your transaction patterns. They know your biggest cash customers. They have documentation you have probably forgotten exists. And they are not there to hear your explanation. They are there to get you on record saying things that will be used against you at trial.
How Jewelry Stores Become Federal Targets
If you are buying and selling $50,000 or more in precious metals, stones, or jewelry annually, congratulations - you are a federally regulated dealer under the Bank Secrecy Act. Most jewelry store owners dont realize this until its too late.
Heres the reality. The federal government considers jewelry businesses high-risk for money laundering. And they are not wrong about the vulnerability - precious metals are portable, valuable, and have subjective pricing. A diamond worth $50,000 can be invoiced at $10,000, letting $40,000 disappear from scrutiny. Criminals know this. The feds know this. The question is wheather you know this.
You are not being targeted because you did something wrong. You are being targeted because your business model looks exactly like a money laundering operation would look. Cash-heavy. High-value inventory. Complex supply chains. International suppliers. Regular customers who always pay cash. Every single one of these normal business practices is a red flag to federal investigators.
The government doesn't need to prove you intended to launder money. They need to prove you were "willfully blind" to suspicious activity - that you ignored red flags you should have noticed. Think about that. Your normal customer service approach - not asking intrusive questions, not demanding to know where someone's money came from - becomes evidence of criminal intent.
This is why the December 2025 case in the Los Angeles Jewelry District should terrify every precious metals dealer in America. Alex Nguyen and his wife Sam Nguyen operated multiple precious metals businesses downtown. Federal investigators discovered they had concealed more than $127 million in cash transactions from the IRS. One hundred and twenty-seven million dollars. The couple admitted they never established an anti-money laundering program for their businesses, despite repeated warnings from IRS auditors that such safeguards were required under federal law.
Read that again. Despite repeated warnings. The IRS told them they needed to comply. They did not. And now those warnings have become evidence of willful non-compliance.
The Willful Blindness Trap
OK so heres were it gets really dangerous for legitimate jewelry store owners.
Under federal law, "willful blindness" means you can be deemed to have known that proceeds came from illegal activity if you ignored red flags. You dont have to actualy know. You dont have to intend anything criminal. You just have to have failed to ask questions that, looking backward, prosecutors will argue you should have asked.
That regular customer who has been buying jewelry for years? Always pays cash? Never asks for reciepts? If he is later arrested for drug trafficking, every transaction with you becomes evidence. And prosecutors will argue that a "reasonable jewelry store owner" would have recognized the warning signs. The fact that he seemed like a nice guy, that he was polite, that you had no reason to suspect anything - none of that matters.
Heres the kicker. FinCEN has published specific red flags for jewelry dealers. If you did not know about them, thats your problem. If you knew about them but did not implement procedures to address them, thats willful blindness. If you had procedures but did not follow them consistantly, thats willful blindness too. The system is basically designed so that something will always be wrong.
This is critical to understand: good intentions do not protect you in federal court. The prosecutor doesn't have to prove you wanted to help criminals. They just have to prove you should have known better and chose not to look.
The legal standard is shockingly low. In 2015, FinCEN brought its first enforcement action against a dealer in precious metals, stones, and jewels. The target was a Los Angeles-based wholesale precious metals business called B.A.K. Precious Metals. The company faced a $200,000 civil penalty. But heres what matters: FinCEN focused on the "willful failure" of the company, through its owner and compliance officer, to assess the company's risks adequately and develop and implement an effective AML program. They did not need to prove actual money laundering. They just proved the company should have done more and did not.
They Can Take Everything Without Convicting You
Let that sink in for a moment.
Under civil asset forfeiture, the federal government can seize your inventory, freeze your bank accounts, and take your store using only "preponderance of evidence" - meaning more likely then not. They dont need to prove you are guilty beyond reasonable doubt. They dont even need to charge you with a crime.
Todd Spodek has seen this pattern destroy jewelry businesses before any trial happens. The government files a civil forfeiture complaint against your property itself - not against you. Your diamonds, your gold, your display cases, your cash register contents - all of it becomes the defendant. And property dosent have constitutional rights the way people do.
The statistics are devastating. Federal asset forfeiture has grown exponentially over the past four decades. Most cases are uncontested because fighting forfeiture requires hiring lawyers while your assets are frozen. Its a perfect trap. They take your money so you cant afford to fight them taking your money.
Even if you eventualy win - even if you are never charged with anything - getting your property back takes years. By then, your business is gone. Your employees have moved on. Your suppliers will not extend credit to someone whose store was seized by federal agents. The damage is done whether you are convicted or not.
The Nguyen case in Los Angeles illustrates this perfectly. The money laundering charges alone carry a maximum sentence of 60 years in prison and a fine of up to $500,000. But the real damage happens before sentencing. The moment those charges were filed, bank accounts froze. Suppliers stopped calling back. Employees started looking for new jobs. The business was effectivly dead before any verdict.







