AML compliance for dealers in precious metals and stones

The headline trigger is A$10,000 (or the foreign-currency equivalent) in cash or cash-equivalent for a single designated transaction, which generates a Threshold Transaction Report (TTR) lodged with AUSTRAC within 10 business days. Equally important are the structuring rules: a series of sub-threshold transactions designed to avoid the TTR (for example, three A$4,500 cash purchases over a fortnight by the same buyer) is itself an offence and a Suspicious Matter Report trigger. Modern dealer AML platforms aggregate purchases by customer, payment method, and time window so structuring patterns are flagged automatically rather than relying on counter-staff memory.

No. The Tranche 2 designated services target dealing in precious metals (gold, silver, platinum, palladium) and precious stones (diamonds, sapphires, rubies, emeralds) above prescribed thresholds. Costume jewellery, fashion accessories, plated items, and low-value gemstones are outside scope. Mixed-inventory retailers (a high-end jeweller selling both fine and fashion ranges) need a program scoped to the precious side of the business, with a clear point-of-sale rule that distinguishes which transactions trigger CDD and which do not. Providers help you encode that rule into the POS workflow so it is consistent across staff.

Cash is the most common trigger but not the only one. Large card-not-present payments, international wires, cryptocurrency settlement, and bullion-for-bullion swaps can all attract CDD, source-of-funds, and reporting obligations depending on amount, jurisdiction, and risk indicators. International funds transfers carry their own International Funds Transfer Instruction (IFTI) reporting obligation in addition to TTR. The practical rule for dealers is that the payment method changes the reporting form — it does not change whether you need to know your customer.

Online sales of bullion, investment-grade jewellery, and high-value stones are squarely in scope. Identity verification has to happen before the designated service is provided — that means at checkout or before dispatch, not after. Several CompareAML providers offer an online-checkout integration that runs a digital ID flow, sanctions and PEP screening, and source-of-funds prompts in under three minutes for standard customers, with manual review for higher-risk patterns. Auction houses dealing in precious metals or stones above threshold have analogous obligations and typically run CDD at the bidder-registration stage.

Storing precious metals or stones on behalf of clients (vault and custody services) is itself a designated service under the Tranche 2 list. Custody operators have CDD obligations on the customer, beneficial owner, and any authorised third party with access rights, plus ongoing monitoring for unusual deposit and withdrawal patterns. The risk profile differs from point-of-sale: custody flags long-term concealment patterns rather than single large purchases, so the program should include periodic reviews of dormant accounts, third-party access changes, and large transfers in or out.