Dealers in precious metals, stones and products operate with two frameworks: bullion dealing, which has been regulated since Tranche 1, and the broader precious-items regime introduced with Tranche 2, which uses a physical-currency or virtual-asset threshold. A transaction-level checklist is essential because the obligations attach to individual transactions and linked series, not to a dealer licence. This guide sequences the work: classify the product, test the threshold, complete CDD, monitor linked transactions and report.
Classify the product and the service
The legal treatment differs by product and service. A dealer should document the classification for each line - bullion, coins, jewellery, stones, scrap and products - so the threshold and CDD decisions are traceable.
- Distinguish bullion dealing from non-bullion precious-items sales
- Confirm which item and threshold apply to each product line
- Record the classification for gold, silver, stones and finished products
- Check whether the dealer is separately registered for bullion
Test the threshold and complete CDD
For non-bullion precious items, the threshold test drives whether CDD applies to the transaction. The dealer should capture the value, the payment method and the customer's identity before the deal completes, and keep the evidence with the transaction record.
- Identify the transaction value and the payment method
- Apply the physical-currency or virtual-asset threshold to the captured item
- Complete applicable customer identification before the transaction
- Screen for PEPs, sanctions and adverse media
- Record the risk rating and the reason
Linked transactions and cash
The dealer sector is built for linked-transaction abuse: a customer splits purchases to stay below thresholds. AUSTRAC's jeweller guidance includes examples of linked transactions, and the program should define how the dealer detects and records them.
- Identify transactions that may be linked by customer, product or timing
- Apply the aggregation logic the program and guidance require
- Monitor cash activity against the physical-currency threshold
- Escalate deliberate splitting as a structuring pattern
- Lodge TTRs for individual physical-currency transactions at or above A$10,000
Report and retain
The counter is where the pattern appears: the same customer, different stores, similar products, cash payments. A transaction-level record with a customer link makes the dealer's monitoring real rather than a policy statement.
- Lodge SMRs where the transaction or pattern creates reasonable suspicion
- Protect SMR-related information from tipping off
- Lodge TTRs within 10 business days
- Retain transaction, CDD and screening records for the required period
- Train counter staff on the thresholds and escalation path
Official sources
Confirm the current rules against these primary sources.
Questions
Which precious-items sales are captured?
The capture depends on the product and the applicable item and threshold. Bullion dealing is separately regulated; non-bullion precious items use the physical-currency or virtual-asset threshold.
When must a dealer complete CDD?
Where the transaction is a designated service, applicable customer identification must be completed before the transaction. The threshold test should happen before the deal, not after.
How do linked transactions work?
Transactions linked by customer, product or timing can be treated as one transaction for the relevant obligation. AUSTRAC's jeweller guidance includes examples; the program should define the dealer's detection method.
What reports does a dealer file?
TTRs for individual physical-currency transactions at or above A$10,000, SMRs where suspicion is formed, and any IFTI or other reports the dealer's services require.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
- For precious metals dealers6 min
Australian AML/CTF obligations for jewellers, precious-metals, stones and products dealers and bullion dealers: regulated items, payment thresholds, linked transactions, CDD and reporting.
- Linked precious-item transactions6 min
How jewellers and precious-items dealers identify linked cash and virtual-asset payments, recognise the A$10,000 service threshold and keep TTR analysis separate.
- Jeweller AML/CTF obligations6 min
A practical guide to when Australian jewellers are regulated, what their AML/CTF program must cover and how CDD, linked payments and reporting work at the counter.