AML/CTF Guide for Dealers in Precious Metals, Stones and Products in Australia

Part 1

When AML/CTF May Apply

The 1 July 2026 designated service focuses on covered precious metals, stones and products and the way the customer pays.

• Buying or selling covered items worth $10,000 or more in physical currency.
• Buying or selling covered items worth $10,000 or more in virtual assets.
• Using a mix of physical currency and virtual assets that reaches the threshold.
• Several transactions that are linked or appear linked and together reach the threshold.

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.

• Portable, valuable goods can be bought, moved and resold with little explanation.
• Cash and virtual assets can hide source and reduce the audit trail.
• Payments can be split across days, people or methods to avoid the threshold.
• A buyer and seller may be connected or acting for an undisclosed person.
• Pricing, buy-backs and rapid resale can be used to move value.

Part 3

A Practical Control Plan

1. Step 1

   Confirm scope

   Identify which stock is a precious metal, stone or product under the Act.

2. Step 2

   Build the customer process

   Decide whether cash or virtual-asset transactions will be accepted and document the operating model.

3. Step 3

   Set the risk controls

   Build a system that joins linked payments, invoices, people and purchases.

4. Step 4

   Train and connect people

   Design the sales process so required CDD is completed before providing a designated service, and monitor linked transactions from the first physical-currency or virtual-asset payment.

5. Step 5

   Test and improve

   Test threshold, linked-transaction, refund, buy-back and suspicious-matter 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.

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 documented list of covered metals, stones and products.
• A linked-transaction report across invoices, staff, stores and payment methods.
• CDD and reporting records tied to the sale, item and payment trail.
• Clear records for refunds, exchanges, buy-backs and virtual-asset payments.
• Customer, beneficial ownership, risk, monitoring and reporting records.
• Training, internal review, independent assurance and remediation records.

Part 6

Common Mistakes

• Looking at each instalment or store visit separately.
• Counting non-precious items toward the threshold.
• Treating card and bank-transfer purchases as this designated service.
• Completing CDD only after the threshold has already been crossed.
• Failing to assess whether a refused or proposed regulated transaction creates reasonable grounds for suspicion.