Dealer in Precious Metals, Stones and Jewels

We are trying to determine whether or not a customer qualifies as a dealer of precious metal, precious stones or jewels and if so, what is required with regard to AML and OFAC. The customer sells jewelry on Etsy to the general public including rings, earrings and necklaces. Most of the rings come with a gemstone. The metal of the ring is made with sterling silver, 10K gold and 14k gold. Gemstones include aquamarine, cubic zirconia, alexandrite, lab (man-made) sapphire, lab created ruby, lab created emerald, amethyst, moonstone, blue topaz, garnet, quartz, period and morganite. The customer purchases approximately $150,000 from foreign vendors in Hong Kong. - Does this customer qualify as a dealer in precious metals, stones and jewels? - And if the customer does qualify, what documentation does the customer need to have in place with regard to an AML program, OFAC, risk assessment, etc.? - How are dealers in precious metals, gemstones and jewels advised that they are required to have this documentation? - Are they regulated, and if so by who? Any insight you could provide would be greatly appreciated.