AML/CTF Guide for Bullion Dealers in Australia
Australian bullion dealers are an established regulated sector. Buying, selling, account, storage, transfer and payment arrangements should be mapped to the applicable designated services. This guide explains scope, sector risks, practical controls, examples and official sources in plain English.
How this guide was researched and reviewedOn this page
Short answer
Australian bullion dealers are an established regulated sector. Buying, selling, account, storage, transfer and payment arrangements should be mapped to the applicable designated services.
Scope is based on each designated service, the business test and the geographical link. Check current exemptions and modifications before relying on a result.
At a glance
Start With These Four Checks
Map the service
Write down exactly what is done for the customer and match it to section 6.
Know the customer
Identify the customer, beneficial owners, people acting for them and the purpose of the work.
Follow the sector risk
Build controls around how money, property, structures, products and instructions move in this sector.
Keep the evidence
Scope, CDD, risk, monitoring, reports, training and review should be easy to prove.
Plain English
Key Words Explained
These words are used in the law and official guidance. This is what they mean on this page.
- Designated service
- A service listed in section 6 of the Australian AML/CTF Act.
- Reporting entity
- A person or business that must meet AML obligations for the covered service or activity.
- Beneficial owner
- The individual who ultimately owns or controls the customer or on whose behalf the work is done.
- Enhanced CDD
- Extra customer and source checks used when the law or higher risk requires them.
- SMR
- A suspicious matter report submitted to AUSTRAC when reasonable grounds for suspicion exist.
Part 1
When AML/CTF May Apply
Bullion is portable, valuable and can be traded or stored. The legal analysis should distinguish bullion services from the newer precious-products threshold service.
- Buying or selling bullion in the course of a bullion business where the designated-service conditions are met.
- Opening or operating relevant bullion or value accounts.
- Storing, transferring or delivering bullion through another designated service.
- Accepting cash, virtual assets or other payments that trigger reporting or monitoring duties.
- Providing another financial, remittance or precious-products designated service.
Bullion and precious-products rules can overlap but are not identical. The form of the metal, service, customer and payment method should be mapped to the correct part of section 6.
Part 2
Main Risks in This Sector
These are starting points, not a ready-made risk rating. The business still needs to assess its own customers, services, countries, channels, transactions and technology.
- Bullion can store large value in a portable and easily traded form.
- Cash, virtual assets and third-party payments can hide source.
- Buy-back, storage and delivery instructions can move value without an obvious bank trail.
- Dealers, intermediaries and overseas counterparties can obscure the real customer.
- Pricing, purity and invoice manipulation can disguise value.
Part 3
A Practical Control Plan
- Step 1
Confirm scope
Map bullion products, buy-backs, storage, delivery, accounts and payment methods.
- Step 2
Build the customer process
Distinguish bullion designated services from precious-products threshold services.
- Step 3
Set the risk controls
Join customer, payment, wallet, delivery and related-party information.
- Step 4
Train and connect people
Set enhanced controls for cash, virtual assets, third parties, overseas trade and unusual buy-backs.
- Step 5
Test and improve
Reconcile threshold and suspicious reports with sales, purchase and inventory records.
Part 4
Worked Examples
These examples show how the scope and risk questions can be joined. They do not replace the law or the facts of a real matter.
| Situation | Why it matters | Practical response |
|---|---|---|
| A customer buys bullion with funds from several unrelated people. | The true source and beneficial owner of the bullion may be hidden. | Identify the funders, understand the arrangement and apply enhanced checks and reporting assessment. |
| Bullion is bought, stored briefly and sold back for payment to another account. | The cycle may be used to transform or redirect value. | Review the whole sequence, ownership, payment path, commercial reason and related parties. |
| An overseas intermediary arranges delivery to a third party. | The customer, recipient and controller may be different people. | Resolve each role, check country and sanctions risk and document authority and purpose. |
Part 5
Evidence That Should Be Easy to Find
- The designated-service and geographical-link analysis.
- The current sector risk assessment and the official sources used.
- A service map distinguishing bullion and precious-products rules.
- Sales, purchases, storage, delivery, buy-back and inventory records linked to the customer.
- Source, third-party, virtual-asset and overseas counterparty checks.
- Reconciliation of transactions, inventory movements and regulatory reports.
- Customer, beneficial ownership, risk, monitoring and reporting records.
- Training, internal review, independent assurance and remediation records.
Part 6
Common Mistakes
- Applying the jeweller threshold rule to every bullion service.
- Looking at the purchase without storage, delivery or buy-back activity.
- Accepting a third-party payment without identifying the relationship.
- Failing to join activity across branches, accounts and related customers.
- Treating physical possession as proof of ownership or source.
Helpful answers
Common Questions
Short answers to the questions businesses ask most often.
Does every business in this sector have AML/CTF duties?
No. The exact service and the other legal tests decide the answer. A business may provide both designated and non-designated services.
What should the business do first?
Map bullion products, buy-backs, storage, delivery, accounts and payment methods.
Can the sector risk assessment replace our own?
No. Official national and sector assessments are important sources, but the reporting entity must assess the risks it reasonably expects to face in its own business.
Can a generic AML/CTF template be used?
A template can help with structure, but it must be matched to the business’s scope, risks, people, systems and evidence. A document that is not implemented is not enough.
Are bullion and jewellery covered by the same rule?
Not always. Bullion has established designated services, while the precious metals, stones and products service added in 2026 has its own item and payment threshold. Map the exact product and service.
Does storage matter?
It can affect the service, customer relationship and risk. Storage, account, transfer and delivery arrangements should be included in the scope and risk assessment.
Reference
Official Sources
This guide cites the following sources.
- Primary lawFederal Register of LegislationAnti-Money Laundering and Counter-Terrorism Financing Act 2006
The current Australian AML/CTF Act, including program, CDD, reporting, governance and record-keeping duties.
- Regulator guidanceAUSTRACBullion dealers
Current AUSTRAC guidance and resources for bullion dealers and businesses that buy, sell or store bullion.
- Regulator guidanceAUSTRACWho and what we regulate
The activities-based test for deciding whether a business is a reporting entity.
- Regulator guidanceAUSTRACDevelop your AML/CTF program
The five-part process for governance, risk assessment, policies, review and independent evaluation.
- Regulator guidanceAUSTRACCustomer due diligence
Current guidance on initial, ongoing, simplified and enhanced customer due diligence.