--- title: "Precious Metals Sector AML/CTF Compliance | HeadStart Docs" description: "AML/CTF compliance for Australian precious metals, stones and product dealers under Tranche 2. $10,000 threshold, cash transactions, customer ID. Download free report." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 AML/CTF obligations commence on 1 July 2026. 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Only dealers in precious stones, precious metals and other prescribed products are covered." } }, { "@type": "Question", "name": "What products are covered besides gold and diamonds?", "acceptedAnswer": { "@type": "Answer", "text": "The legislation covers precious metals (gold, silver, platinum group metals), precious stones (diamonds, sapphires, emeralds, rubies) and other prescribed products like pearls and certain semi-precious gems." } }, { "@type": "Question", "name": "Do jewellers need AML/CTF compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, jewellers dealing in precious metals and stones above the $10,000 cash threshold are reporting entities and need a compliant AML/CTF program." } } ] }, { "@context": "https://schema.org", "@type": "HowTo", "name": "How to Prepare for AML/CTF Tranche 2 as a Precious Metals Dealer", "description": "Step-by-step guide for precious metals, stones and other product dealers to prepare for AML/CTF Tranche 2 compliance before July 2026.", "totalTime": "P180D", "step": [ { "@type": "HowToStep", "position": 1, "name": "Confirm your products are covered", "text": "Verify that your products (precious metals, stones or other prescribed products) and transaction values trigger AML/CTF obligations." }, { "@type": "HowToStep", "position": 2, "name": "Appoint an AML/CTF Compliance Officer", "text": "Designate a senior person to oversee AML/CTF compliance and act as the primary contact with AUSTRAC." }, { "@type": "HowToStep", "position": 3, "name": "Conduct a risk assessment", "text": "Assess your exposure to money laundering, terrorism financing and proliferation financing risks based on your products and transaction patterns." }, { "@type": "HowToStep", "position": 4, "name": "Develop your AML/CTF program", "text": "Create policies and procedures documents tailored to your precious goods dealer operations." }, { "@type": "HowToStep", "position": 5, "name": "Establish customer identification procedures", "text": "Implement identity verification procedures for cash sales and high-value transactions above the threshold." }, { "@type": "HowToStep", "position": 6, "name": "Set up cash handling and reporting", "text": "Implement procedures for cash transactions, threshold transaction reporting and structuring detection." }, { "@type": "HowToStep", "position": 7, "name": "Develop trade-in and exchange protocols", "text": "Create AML/CTF procedures for trade-ins, exchanges and part-payment transactions." }, { "@type": "HowToStep", "position": 8, "name": "Train staff on suspicious indicators", "text": "Provide training on red flags specific to precious goods transactions and suspicious activity reporting." }, { "@type": "HowToStep", "position": 9, "name": "Enrol with AUSTRAC before July 2026", "text": "Register with AUSTRAC as a reporting entity before the Tranche 2 commencement date." }, { "@type": "HowToStep", "position": 10, "name": "Schedule regular program reviews", "text": "Plan for annual reviews of your AML/CTF program and risk assessment." } ], "author": { "@type": "Organization", "name": "HeadStart Docs" } }, { "@context": "https://schema.org", "@type": "WebPage", "name": "Precious Metals Sector AML/CTF Compliance", "url": "https://www.headstartdocs.com.au/precious-metals", "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".sector-hero-description", ".faq-section", ".compliance-obligations" ] } } ] --- We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) Precious Metals Sector # Dealers in precious metals and stones above threshold values are designated reporting entities. Here's what you need to know before 1 July 2026. From 1 July 2026, new AML/CTF compliance obligations (called Tranche 2) will apply to Dealers in Precious Metals, Stones and Other Products. AUSTRAC enrolment opens 31 March 2026. ![Dealers in precious metals and stones above threshold values are designated reporting entities. Here's what you need to know before 1 July 2026. professionals](/assets/precious-metals-shop-new-OVG-VQCp.jpg) ## The path to 1 July 2026 is defined by clear legislative and regulatory milestones AML/CTF Amendment Act Passed Nov 2024 Finalisation of AML/CTF Rules Aug 2025 Core Guidance from AUSTRAC Oct 2025 Sector-Specific Guidance Early 2026 AUSTRAC Enrolment Opens 31 Mar 2026 Mandatory Compliance Commences 1 Jul 2026 International bodies and Australian regulators view dealers in precious goods as high-risk. Criminals are attracted to these products because they can be bought and sold with limited identification and are easy to conceal and transport. ## Why this sector is a focus for regulators International bodies and Australian regulators view dealers in precious goods as high-risk. Criminals are attracted to these products because they: 1. Can be bought and sold with limited identification. 2. Do not always require proof of ownership to sell. 3. Are compact, easy to conceal, transport and smuggle. 4. Can be melted, recut, or remodelled to disguise their origin. 5. Can be used directly as payment for illicit goods and services. 6. Can be used to mix criminal proceeds into apparently legitimate wealth. The $10,000 Threshold ## Understanding your core trigger ### The Activity You buy or sell precious metals, stones, or products in the course of carrying on a business ### The Value The purchase involves ≥$10,000 in physical currency or virtual assets Payment method matters: Only transactions involving physical currency (cash) or virtual assets (cryptocurrency) are captured. Card payments, BPAY, PayPal and bank transfers are not captured under this designated service. Linked transactions: The $10,000 threshold applies to a single transaction OR several transactions that are linked or appear to be linked (e.g. lay-by arrangements, instalment payments, split invoices). ### Key Definitions (s 5A) #### Precious Metals (s 5A(1)) Gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium, or any alloy with at least 2% weight of these metals. Includes manufactured or unmanufactured state. Examples - • Gold bars - • Silver ingots - • Platinum wire - • Scrap gold #### Precious Stones (s 5A(3)-(5)) Substances with gem quality and market-recognised beauty, rarity and value. Includes natural, synthetic or reconstructed stones. Examples - • Diamonds - • Beryl (emeralds, aquamarine) - • Corundum (rubies, sapphires) - • Garnet, jadeite jade, opal, pearl, topaz #### Precious Products (s 5A(6)) Items made from, containing, or having attached any precious metal or stone. Examples - • Jewellery (rings, necklaces, bracelets) - • Watches with precious metals/stones - • Objects of personal adornment (cufflinks, tie bars) - • Goldsmiths'/silversmiths' wares #### Goldsmiths' or silversmiths' wares include: Ornaments Tableware Smokers' requisites Articles of personal, household, office or religious use ## ML/TF/PF Risks in the Precious Metals Sector Dealers in precious goods face significant money laundering (ML), terrorism financing (TF) and proliferation financing (PF) risks. The compact nature and high value of these products makes them attractive for criminal misuse. #### Identity Verification Customer due diligence Inadequate verification of customer identity leading to onboarding of high-risk clients. #### Unusual Transactions Transaction monitoring Failure to detect structured payments or unusual transaction patterns. #### Sanctions Exposure Prohibited dealings Risk of inadvertently dealing with sanctioned entities or persons. #### Beneficial Ownership Ownership opacity Complex ownership structures obscuring the true beneficial owners of assets or entities. ### Industry References [NRA: Money Laundering (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/money-laundering-australia-national-risk-assessment-2024)• [NRA: Terrorism Financing (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/terrorism-financing-australia-national-risk-assessment-2024)• [NRA: Proliferation Financing (2022) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/proliferation-financing-australia-national-risk-assessment-2022)• [FATF NRA Guidance (2025) ](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) ## Who May Be Captured? The key trigger is transactions at or above $10,000 paid in cash or virtual assets. Jewellers, bullion dealers, pawnbrokers and scrap buyers are all potentially in scope. Bullion dealers Gold, silver and platinum sales Precious stone dealers Diamond and gemstone transactions Jewellers (high-value) Transactions over prescribed thresholds Numismatic dealers Rare coin and collectible transactions Refiners and smelters Processing and refining operations Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines. ## Identifying red flags: a practical guide ### Behavioural Flags (The Customer's Actions) - • Attempts to avoid or minimise ID checks. - • Strong push for anonymity; insistence on using only cash/crypto. - • Use of third parties without a clear commercial reason. - • Requests that you 'forget' or minimise records. - • Nervousness or reluctance when asked about source of funds. ### Profile Flags (The Customer's Story) - • Credible negative media linking the customer to crime. - • Status as a Politically Exposed Person (PEP). - • Lack of interest in the product itself; focus is only on value and liquidity. - • Unusually high volume of activity relative to their apparent wealth or business profile. ### Transactional Flags (The Nature of the Deal) - • Repeated payments structured to stay just below the $10,000 threshold. - • Use of complex ownership structures with no clear business purpose. - • Rapid buying and selling of items, especially at a loss. - • Funds or goods linked to high-risk countries or tax havens without a clear commercial reason. ## Once you are a reporting entity, you have six fundamental compliance obligations ### 1. Enrol with AUSTRAC Formally register your practice as a reporting entity. ### 2. Develop & Maintain an AML/CTF Program Create a written, risk-based program tailored to your firm's specific ML/TF risks. This is the cornerstone of your compliance. ### 3. Conduct Customer Due Diligence (CDD) Identify and verify your clients and their beneficial owners before providing a designated service, and monitor them on an ongoing basis. ### 4. Report to AUSTRAC Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) as required. ### 5. Keep Records Maintain all relevant records of CDD, transactions and your AML/CTF program for prescribed periods. ### 6. Appoint an AML/CTF Compliance Officer Designate a senior individual responsible for the oversight of your program. ## Key AML/CTF Areas for Precious Metals Dealers Under Tranche 2, precious metals dealers face new obligations when conducting high-value cash transactions. Our documentation helps you navigate these requirements with confidence. ### Cash Transaction Controls Procedures for managing and reporting cash transactions at or above the $10,000 threshold. ### Customer Identification Identity verification procedures for customers conducting high-value cash or virtual asset transactions. ### Structuring Detection Procedures to identify linked transactions designed to avoid the $10,000 threshold. ### Trade-In Protocols Compliance requirements for trade-ins, exchanges and part-payment transactions. ### Source of Funds Enquiries Procedures for understanding and documenting the source of funds for high-value purchases. ### Suspicious Matter Reporting Workflows for identifying, escalating and reporting suspicious matters to AUSTRAC. ### Compliance Officer Duties Appointment requirements, role description and ongoing responsibilities for AML/CTF compliance. ## Building an AML Program Building an AML/CTF program for a precious goods dealer requires multiple steps. - AML/CTF program framework for precious goods dealers - Risk assessment worksheet (ML/TF/PF risks) - Customer identification and verification procedures - Cash handling and threshold reporting controls - Trade-in and exchange compliance workflows - Suspicious matter reporting procedures - Staff Training Register for tracking completion - Compliance officer role description ![Professionals reviewing AML compliance documentation](/assets/legal-consultation-SdDZg_6z.jpg) ## Ready to Get Started? We can help you get a headstart on your AML/CTF program. Program packs from $249, licensed to you permanently. Portal is free with managed CDD, or run your own CDD on BYO-API plans from $20/month. ### A HeadStart on Compliance Sector-specific compliance documents to help you build your AML/CTF program. ### Ready-to-Customise Resources Lawyer-ready to review for your business. ### Training & Record-Keeping Staff Training Register, Compliance Officer appointment documents and portal-based training record-keeping. [Get Started - Precious Metals Edition](/programs/precious-metals-aml-program) From $249 inc GST · or bring your own program HeadStart Docs™ products are developed with reference to publicly available regulatory guidance. This is general information only and does not constitute legal or professional advice. You should seek advice specific to your circumstances before making compliance decisions. ## Free Resources [ ### Precious Metals Sector Industry Report Free Tranche 2 Precious Metals Sector Report. What the industry needs to know. ](/reports/precious-metals)[ ### AUSTRAC Starter Kits When will they be out and what to expect. ](/tranche-2-resources/austrac-starter-kit-jewellers)[ ### Tranche 2 Guide Guide to the AML/CTF Amendments and Tranche 2. ](/tranche-2) ### Related Podcast Episode AML for Dealers in Precious Stones, Metals & Other Products • 17:11 Share: [](https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F24BdSG9w2ESehQybMBLp4N)[](https://twitter.com/intent/tweet?text=AML%20for%20Precious%20Metals%20Dealers&url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F24BdSG9w2ESehQybMBLp4N)[]() ### Episode Notes [From $249 ](/programs/precious-metals-aml-program) ### AML/CTF Compliance by Product Type [Jewellers](/precious-metals/jewellers)[Luxury Watch Dealers](/precious-metals/luxury-watch-dealers)[Gold Dealers](/precious-metals/gold-dealers)[Silver Dealers](/precious-metals/silver-dealers)[Platinum Dealers](/precious-metals/platinum-dealers)[Palladium Dealers](/precious-metals/palladium-dealers)[Rhodium Dealers](/precious-metals/rhodium-dealers)[Iridium Dealers](/precious-metals/iridium-dealers)[Osmium Dealers](/precious-metals/osmium-dealers)[Ruthenium Dealers](/precious-metals/ruthenium-dealers)[Diamond Dealers](/precious-metals/diamond-dealers)[Opal Dealers](/precious-metals/opal-dealers)[Pearl Dealers](/precious-metals/pearl-dealers)[Beryl Dealers](/precious-metals/beryl-dealers)[Corundum Dealers](/precious-metals/corundum-dealers)[Garnet Dealers](/precious-metals/garnet-dealers)[Jadeite Dealers](/precious-metals/jadeite-dealers)[Topaz Dealers](/precious-metals/topaz-dealers)[Pawnbrokers](/precious-metals/pawnbrokers)[Alloy Dealers](/precious-metals/alloy-dealers)[Dental Jewellery](/precious-metals/dental-jewellery)[Fashion Accessories](/precious-metals/fashion-accessories) Related Sectors: [TCSP](/tcsp)[Law Practice](/law-practice)[Accounting](/accounting) ### Learn More About Precious Metals Compliance [ Getting Started AUSTRAC Starter Kit for Precious Product Dealers ](/tranche-2-resources/austrac-starter-kit-jewellers)[ Reporting Threshold Transaction Reports ](/tranche-2-resources/threshold-transaction-reports)[ Due Diligence Beneficial Owner Identification ](/tranche-2-resources/beneficial-owner-identification) ### Free Tools for Precious Metals Dealers [Implementation Timeline Key dates and milestones for Tranche 2 compliance ](/timeline)[Readiness Test Assess your compliance readiness in 2 minutes ](/risk-calculator)[Sanctions Screening Search Australian sanctions lists and country risk ](/sanctions-search) ### Related Resources [Precious Metals Report](/reports/precious-metals) ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) [![HeadStart Counsel](/assets/headstart-counsel-logo-dark-DW8mV5rY.png)](https://www.headstartcounsel.com.au/)[![HeadStart Search](/assets/headstart-search-logo-dark-C68UhGXl.png)](/sanctions-search)![HeadStart Verify](/assets/headstart-verify-dark-Dtad3197.png) ### Sectors [Accounting](/accounting)[Business Brokers](/business-brokers)[Buyers Agent](/programs/buyers-agent-aml-program)[Conveyancing](/conveyancing)[Insolvency](/insolvency-practitioners)[Legal](/law-practice)[Nominee Director](/programs/nominee-director-aml-program)[Precious Metals, Stones & Products](/precious-metals)[Property Development](/property-developers)[Real Estate](/real-estate)[TCSPs](/tcsp)[Virtual Address](/virtual-address) ### Resources [Free Resources](/tranche-2-resources)[Decision Trees](/decision-trees)[Tranche 2 Guide](/tranche-2)[Podcast](/podcast)[Free Sector Reports](/sector-reports)[Implementation Timeline](/timeline)[Sanctions Search](/sanctions-search)[AUSTRAC Starter Kits](/tranche-2-resources/austrac-starter-program-kits)[Budgeting for Compliance](/tranche-2-resources/budgeting-amlctf-compliance) ### Programs [Portal + AML Programs](/programs)[Pricing](/pricing)[White Label](/white-label)[External CRMs](/integrations)[AML Portal](/aml-landing)[Plug & Play Technology](/plug-and-play)[Lawyer in the Loop](/features/lawyer-in-the-loop) ### Legal [Terms & Conditions](/terms)[Privacy](/privacy) ### Connect [Programs](/programs)[Podcast](/podcast)[Feedback](/report-problem)[Our Mission](/our-mission)[Partnerships](/partnerships) ### Events [AML Conference 2026](/conference) Powered by Stripe SSL Secured 2026 Ready © HeadStart Docs Pty Ltd (ABN 12 691 347 823). 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