AML/CTF Compliance for Jewellery and Gold Bullion Dealers
Are you prepared for AUSTRAC's heightened scrutiny of the precious metals and jewellery sector?
In short
Since 1 July 2026, Australian jewellers and gold bullion dealers who buy or sell precious metals, stones or jewellery for $10,000 or more in cash are AUSTRAC reporting entities. You must enrol with AUSTRAC, run an AML/CTF program, verify customers, report cash transactions of $10,000+ and suspicious matters, and keep records for seven years.
The precious metals and jewellery industry faces unique AML/CTF challenges due to the high-value, portable nature of gold and precious stones, making these commodities attractive for money laundering activities.
Bullion dealers and jewellers are reporting entities under Australian AML/CTF laws.
Why are gold and jewellery dealers a priority for AUSTRAC?
AUSTRAC classifies bullion dealers and jewellers as high-risk reporting entities due to the sector's vulnerability to money laundering. Gold and precious metals provide an easy way to convert illicit cash into portable, high-value assets that can be easily transported across borders or resold.
Without proper AML/CTF controls, your business risks becoming an unwitting facilitator of money laundering.
What are your AML/CTF obligations as a jeweller or bullion dealer?
If your business deals in:
- Gold bullion - bars, ingots, coins with purity of at least 99.5%
- Precious metals - silver, platinum, palladium in bullion form
- Jewellery - high-value watches, diamonds, precious stones, and luxury jewellery
- Cash transactions - accepting large cash payments for precious items
Then you must comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
Unique Money Laundering Risks in the Gold and Jewellery Sector:
- High-value, low-volume transactions that can quickly convert large amounts of cash
- Portable assets that can easily be transported across borders
- Subjective pricing that makes it difficult to detect overvaluation or undervaluation schemes
- Cash-intensive businesses attracting customers seeking to dispose of illicit funds
- Trade-based money laundering through import/export of precious metals and stones
- Scrap gold schemes used to legitimize cash from criminal activities
How do you build a gold or jewellery AML/CTF program?
Compliance begins with understanding your specific ML/TF Risk Profile. Whether you're a small independent jeweller, a bullion dealer, or a luxury watch retailer, your AML/CTF obligations are tailored to your business model and customer base.
We help you develop a comprehensive AML/CTF Program that addresses the unique vulnerabilities of the precious metals and jewellery sector while remaining practical and implementable for your daily operations.
What must a gold or jewellery AML/CTF program include?
Customer Identification
Robust KYC procedures for all customers, especially those making large cash purchases or frequent transactions
Cash Threshold Reporting
Mandatory reporting of cash transactions over $10,000 and suspicious activity to AUSTRAC
Suspicious Activity Detection
Systems to identify red flags like structuring, unusual purchase patterns, or reluctance to provide ID
Transaction Records
Detailed record-keeping of all high-value transactions, including item descriptions and customer details
Staff Training
Regular training for employees on identifying suspicious behaviour and AML/CTF procedures
Enhanced Due Diligence
Additional verification for high-risk customers and politically exposed persons (PEPs)
What are the money-laundering red flags for gold and jewellery businesses?
Structured Cash Transactions
Multiple purchases just under $10,000 to avoid reporting thresholds, frequent small cash purchases that add up to significant amounts, or customers who appear to be deliberately avoiding identification requirements.
Unusual Purchase or Sale Patterns
Customers purchasing and immediately reselling gold bullion at a loss, buying high-value items with little interest in quality or price, or requesting unusual payment methods like third-party payments or wire transfers from overseas.
International Trade Concerns
Import or export of gold to high-risk jurisdictions, shipments with values that don't match invoice descriptions, or customers involved in cross-border bullion movements without clear legitimate business purposes.
Customer Behavior Indicators
Reluctance to provide identification or business details, appearing nervous or evasive when asked routine questions, providing inconsistent information about source of funds, or requesting invoices with false descriptions.
How does SNS Accounting support jewellers and bullion dealers?
We understand the practical challenges facing bullion dealers and jewellers. Our team has extensive experience helping precious metals and jewellery businesses implement AML/CTF programs that are both compliant and practical for day-to-day operations. We've worked with businesses ranging from small independent jewellers to large bullion dealers and luxury watch retailers.
We have worked with:
Our services for gold and jewellery businesses include:
- ML/TF Risk Assessment tailored to precious metals and jewellery sector
- Development of practical AML/CTF Programs for bullion and jewellery businesses
- Customer identification and verification procedures
- Threshold Transaction Report (TTR) and Suspicious Matter Report (SMR) guidance
- Red flag identification training for staff
- Independent Reviews of your AML/CTF Program
- AUSTRAC registration and ongoing compliance support
- Response to AUSTRAC inquiries and enforcement actions
- Record-keeping systems and document retention guidance
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Jewellery and bullion AML/CTF questions answered
What Australian jewellers and gold dealers ask us most about AUSTRAC and Tranche 2.
Do jewellers and bullion dealers have to register with AUSTRAC?
Yes, if you provide a designated service. Under the Tranche 2 reforms, dealers in precious metals and stones are captured when they buy or sell bullion, precious stones or jewellery in a transaction involving $10,000 or more in physical cash. Businesses that only accept card or bank transfer for high-value sales are generally outside the regime, but you must document how you reached that conclusion. Enrolment is done through AUSTRAC Online within 28 days of first providing the service.
What does a jewellery or gold AML/CTF program have to contain?
A written money-laundering and terrorism-financing risk assessment for your business, AML/CTF policies approved by senior management, a named compliance officer, customer identification and verification procedures, ongoing customer due diligence and transaction monitoring, staff training, an employee due diligence program, and an independent review at least every three years. AUSTRAC expects the program to be proportionate to your size and risk, not a copy of a bank's.
What transactions must a gold dealer report to AUSTRAC?
Threshold transaction reports for any physical cash payment or receipt of $10,000 or more (in one transaction or structured across several), due within 10 business days. Suspicious matter reports whenever you form a suspicion about a customer, transaction or attempted transaction, due within three business days, or 24 hours if it relates to terrorism financing. Reports are lodged through AUSTRAC Online and must never be disclosed to the customer.
What are the red flags for money laundering in the jewellery and bullion trade?
Customers who split purchases to stay under $10,000, pay large sums in cash with no interest in price or provenance, ask to buy and immediately resell, use third parties or refuse identification, request delivery to unrelated addresses, or trade volumes inconsistent with their stated occupation. Repeated purchases of small, highly liquid items such as one-ounce bars and loose diamonds are a particular concern. Each red flag should prompt enhanced due diligence and possibly a suspicious matter report.
What are the penalties for non-compliance?
AUSTRAC can issue infringement notices, remedial directions and enforceable undertakings, and can seek civil penalties in the Federal Court that run to millions of dollars for corporations, with separate penalties for individuals involved. Trading while unenrolled and failing to report are civil penalty contraventions; tipping off a customer is a criminal offence. Reputational damage and loss of banking relationships usually follow public enforcement action.
How does SNS Accounting help jewellers and bullion dealers comply?
We confirm whether you are a reporting entity, complete your AUSTRAC enrolment, write your risk assessment and AML/CTF program, set up practical customer identification and cash reporting procedures that fit a retail counter, train your staff, and act as an ongoing point of contact for reporting questions. Fees are fixed and quoted in advance. This page is general information, not legal advice; we will confirm the position for your specific business.