Regulatory Briefing

AML/CTF obligations for dealers in bullion precious metals stones & products

What every bullion dealer, jeweller, gold and silver exchange, coin dealer, refiner and pawnbroker must now do under the AML/CTF Act 2006 (Cth).

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Legislative Framework

What changed and when

The core obligations sit in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), supported by the AML/CTF Rules 2007 and AUSTRAC guidance. The Act was substantially amended by the AML/CTF Amendment Act 2024, which extended reporting entity status to new "tranche 2" sectors — real estate agents, lawyers and conveyancers, accountants, and dealers in precious metals, stones and products — with obligations commencing 1 July 2026.

Relevant provisions include sections 5 and 5A (definitions of bullion, precious metal, precious stone, precious product), section 6 (designated services, Table 2), section 39E (CDD exemptions), section 41 (suspicious matter reports), Part 3 (reporting) and Part 15 (AML/CTF programs).

Two Overlapping Pathways

Bullion dealing — already regulated

Buying or selling bullion in the course of carrying on a bullion-dealing business is a designated service with no dollar threshold — it applies from the first transaction, including wholesale purchases.

Precious metals stones & products — new from 1 July 2026

A designated service where a transaction — or linked series of transactions — involves physical currency and/or virtual assets totalling $10,000 or more. Card and bank-transfer payments alone do not trigger this designated service.

Linked Transactions & Structuring

Why the $10,000 threshold is easy to miss

Transactions count toward the $10,000 threshold if they relate to the same sale, form part of one arrangement (e.g. lay-by), share a common purpose, are made by the same customer in a short period, or are connected through the same invoice or payment. Where only part of a sale involves regulated items, only the regulated portion counts toward the threshold.

Deliberately splitting payments to stay under $10,000 is structuring — a criminal offence. A suspicious matter report is required wherever a business has reasonable grounds to suspect structuring, even if it declines the transaction.
Core Obligations

What being regulated actually requires

§ 5.1

Enrol with AUSTRAC

Mandatory before providing any designated service — requires ABN/ACN, business details, services provided, turnover, and compliance officer details.

§ 5.2

Maintain an AML/CTF Program

A written, senior-management-approved program: Part A (risk-based systems & controls) and Part B (employee due diligence).

§ 5.3

Appoint a Compliance Officer

A management-level person with authority to run the program and liaise with AUSTRAC. Notification required within 14 days.

§ 5.4

Customer Due Diligence

Initial, ongoing and enhanced CDD depending on risk — PEPs, high-risk jurisdictions, or suspected structuring trigger enhanced CDD regardless of value.

§ 5.5

Transaction Monitoring

A system — not just staff judgement — to flag same-customer or same-arrangement purchases that could cumulatively reach $10,000.

§ 5.7

Record Keeping

Retain CDD, transaction and reporting records for at least 7 years, in a form producible to AUSTRAC on request.

Consequences

What's at stake for non-compliance

Providing a designated service while unenrolled, failing to maintain an adequate program, or failing to report on time are each civil penalty provisions under the Act, and can also expose individuals to criminal liability (e.g. structuring offences). AUSTRAC has stated it will take a "pragmatic and proportionate" approach to genuine transitional gaps where a business has a documented remediation plan — but expects unmanaged risk or unmet obligations to attract regulatory action.

Immediate Action Checklist

Where to start today

Sources: Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), compilation C2026C00274 — sections 5, 5A, 6, 39E, 41; AUSTRAC guidance on bullion dealers and on precious metals, stones and products designated services, current to 30 July 2026.

This page is general regulatory information, not legal advice. Clients should obtain independent legal advice on how the Act applies to their specific circumstances. AUSTRAC continues to publish and update sector-specific guidance — this briefing should be re-checked before relying on it for a specific engagement.

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