What is the policy? 

You must be vetted and approved by the Walmart AML (Anti-Money Laundering) Compliance team to sell covered goods on Walmart Marketplace. The Financial Crimes Enforcement Network (FinCEN) defines “covered goods” as jewels, precious metals, precious stones and finished goods that derive at least half of their value from jewels, precious metals or precious stones.

Because covered goods present a higher risk for crimes such as money laundering and terrorist financing, sellers of covered goods must comply with specific federal laws and economic sanctions regulations. If you or your business fail to maintain the following requirements and agreements, Walmart has the right to unilaterally terminate your Marketplace Retailer Agreement with no cost or penalty to Walmart regardless of any other provision in these agreements. 

As a seller of covered goods on Walmart Marketplace, you agree to: 

• Comply with the regulations described in the Code of Federal Regulations, Title 31, Part 1027 – Rules for Dealers in Precious Metals, Precious Stones, or Jewels. 

• Provide accurate and up-to-date information about your business during the Walmart Marketplace onboarding process, and during the time that you sell covered goods on Walmart Marketplace. Walmart uses this information to determine whether a business must comply with the anti-money laundering regulations specified in Title 31, Part 1027 of the Code of Federal Regulations.  

• Complete a detailed vetting process. This process allows Walmart to understand your business and ensure your compliance with anti-money laundering regulations. 

• Submit information about your business as part of the vetting process, including: 
  

• Identity verification. Walmart will confirm the legitimacy of your business and its beneficial owners (all persons who have 10% or more ownership in your business entity). You may also be required to provide personally identifying information such as your Social Security number, driver’s license number or national identification number.

• Business documentation. Walmart will ask you to provide a description of your business, along with documentation of what types of products you sell; the countries of origin and countries of mining of your products; information about your suppliers and their countries of origin; how you operate; and the purpose of your business and its sales patterns. 

• Anti-money laundering documentation. You may also need to provide a description of your anti-money laundering program, including documentation of:

• Your anti-money laundering policies and procedures.

• Your designated compliance officer.

• An annual employee training program. 

• An annual independent audit and review of your anti-money laundering program, and the audit’s results.

To request covered goods approval for your business, select the Help button in the Seller Center menu bar and contact Support. Then complete and return the anti-money laundering questionnaire and the requested documentation.

Additional guidelines 

Sellers of covered goods must comply with laws prescribed and enforced by the United Nations, the Bank Secrecy Act, the Office of Foreign Assets Control (OFAC) and local economic sanctions regulations. These laws have been enacted to prevent illegal transactions with sanctioned people, entities and geographies. 

If you’re approved to sell covered goods on Walmart Marketplace, you must: 

• Keep your business information accurate and up to date. 

• Immediately report any concerns, unusual transactions or sanctions regulation violations to Walmart.  

• Provide information required by Walmart’s anti-money laundering program, such as:
  

• The beneficial owners (all persons who have 10% or more ownership in your business entity), controlling persons and compliance officers of your business.

• Any restrictions or suspensions of your Walmart Marketplace sales.

• Transaction limits.

• Delayed or canceled transactions. 

• If warranted, establish an anti-money laundering program that meets Bank Secrecy Act requirements, including:

• Designate a compliance officer to oversee your anti-money laundering program.

• Provide your employees with ongoing training.

• Test your anti-money laundering program through regular and independent audits.

• File all required regulatory reports and maintain written anti-money laundering policies, procedures and controls. 

• Maintain anti-money laundering and OFAC programs in accordance with U.S. law and federal regulations.  

• Indemnify Walmart for any and all damages incurred by Walmart or any of its affiliates due to failure to maintain sufficient anti-money laundering and OFAC programs.  

• Inform Walmart within seven business days of: 
  

• Any adverse regulatory action taken against you regarding anti-money laundering or OFAC matters.

• Any less than satisfactory assessment of your anti-money laundering or OFAC program by a regulator or an independent third party.  

• Work with Walmart to identify, investigate and perform due diligence on potentially fraudulent, unusual, unlawful or suspicious activities.  

• Share all data concerning such activities with Walmart to the fullest extent permitted by law.