If you sell, buy, or deal in precious metals, precious stones, or jewellery in Australia, you are now a reporting entity under the AML/CTF Act. AUSTRAC enrolment opened on 31 March 2026, and full obligations begin 1 July 2026. With fewer than 80 days to go, here's your complete guide.
Why Jewellers Are Now Regulated
Precious metals and stones have been used for money laundering for centuries. They're attractive because:
- High value, small size — a $50,000 gold bar fits in your pocket
- Globally fungible — gold is gold, regardless of where it was purchased
- Cash-intensive industry — large cash payments are still common in the trade
- Difficult to trace — once melted or re-cut, the origin of metals and stones is nearly impossible to determine
- Alternative value store — criminals use precious metals to park illicit wealth outside the banking system
Australia's FATF mutual evaluation identified the precious metals and stones sector as a significant gap in AML/CTF coverage. Tranche 2 closes that gap.
What Counts as a "Designated Service"?
Not every jewellery transaction triggers AML/CTF obligations. The Act specifies designated services for the sector:
Covered Activities
| Designated Service | Threshold |
|---|---|
| Buying precious metals (gold, silver, platinum, palladium) | $10,000 or more (single or linked transactions) |
| Selling precious metals | $10,000 or more |
| Buying precious stones (diamonds, rubies, sapphires, emeralds) | $10,000 or more |
| Selling precious stones | $10,000 or more |
| Manufacturing jewellery using customer-supplied precious metals/stones | $10,000 or more (value of materials) |
| Refining or smelting precious metals | $10,000 or more |
Not Covered (Below Threshold)
- Retail jewellery sales under $10,000 (e.g., selling a $3,000 engagement ring)
- Watch repairs and servicing
- Costume jewellery or fashion accessories
- Jewellery valuations and appraisals (unless part of a purchase/sale)
Critical point: The $10,000 threshold applies to linked transactions. If a customer buys $6,000 of gold today and $5,000 tomorrow, and the transactions are related, they exceed the threshold and CDD is required.
Your Core Obligations
1. Enrol with AUSTRAC
Enrolment is open now at AUSTRAC Online. You must enrol before providing designated services from 1 July 2026. The registration deadline is 29 July 2026, but don't wait — enrol now while it's fresh.
2. Develop an AML/CTF Program
Your program must cover Parts A through F:
| Part | What It Covers |
|---|---|
| Part A | Governance, risk assessment, compliance officer appointment |
| Part B | Employee due diligence, training, ongoing screening |
| Part C | Customer identification and verification (CDD) |
| Part D | Transaction monitoring procedures |
| Part E | Reporting obligations (SMRs, TTRs) |
| Part F | Record keeping and program review |
AUSTRAC has published a jeweller-specific starter kit with templates and examples tailored to the sector.
3. Conduct Customer Due Diligence (CDD)
Before completing any designated service, you must:
- Identify the customer — collect full name, date of birth, residential address
- Verify their identity — check government-issued photo ID (driver's licence, passport)
- Assess their risk — is this a one-off purchase or an ongoing relationship? Are there any red flags?
- Identify beneficial owners — if the customer is buying on behalf of a company or trust, identify who ultimately owns or controls it
- Screen against sanctions lists — check the DFAT consolidated sanctions list
For transactions at or above $10,000, this is mandatory. No exceptions.
4. Monitor Transactions
You don't need complex software to monitor transactions — but you do need a system. Watch for:
- Multiple transactions just below $10,000 (structuring)
- Customers who pay entirely in cash for high-value purchases
- Customers who seem uninterested in the quality or value of what they're buying
- Requests to buy and then immediately resell
- Transactions that don't match the customer's apparent financial profile
5. Report Suspicious Matters
If you form a suspicion that a transaction may be related to money laundering or terrorism financing, you must file a Suspicious Matter Report (SMR) with AUSTRAC:
- Within 3 business days for money laundering suspicions
- Within 24 hours for terrorism financing suspicions
You must not tip off the customer that a report has been filed. Tipping off is a criminal offence.
6. Report Threshold Transactions (TTRs)
Any cash transaction of $10,000 or more must be reported to AUSTRAC via a Threshold Transaction Report (TTR) within 10 business days. This applies whether the transaction is suspicious or not — it's purely based on the cash amount.
7. Keep Records
All CDD records, transaction records, and reports must be kept for 7 years. This includes:
- Copies of identification documents
- Transaction receipts and invoices
- SMRs and TTRs filed
- Training records for staff
- Your AML/CTF program and any updates
Red Flags Specific to Jewellers
AUSTRAC's jeweller typologies highlight these suspicious patterns:
Cash Red Flags
- Customer pays $50,000+ in cash with no reasonable explanation
- Customer makes multiple purchases of $9,000–$9,999 to avoid the $10,000 TTR threshold (structuring)
- Customer uses different names or different staff members for sequential cash purchases
- Cash appears to be pre-counted in exact amounts, suggesting professional handling
Purchase Behaviour Red Flags
- Customer shows no interest in quality, design, or certification — they just want the metal or stone
- Customer buys bullion or uncut stones rather than finished jewellery (higher laundering utility)
- Customer requests immediate resale or buyback shortly after purchase
- Customer pays a premium without negotiation for items that are typically negotiated
- Multiple purchases in a short timeframe with no reasonable personal use
Customer Red Flags
- Customer is reluctant to provide ID or provides inconsistent identification
- Customer is acting as an agent for an unnamed principal
- Customer is on the DFAT sanctions list or is a politically exposed person (PEP)
- Customer provides a business card from an unrelated industry and can't explain the connection to precious metals
- Customer requests delivery to a third party or overseas address
Trade-Specific Red Flags
- Supplier offers precious metals at significantly below market price
- Scrap gold purchases from individuals with large quantities and no clear source
- Requests to melt down recently purchased jewellery (destroying traceability)
- Customers from high-risk jurisdictions purchasing portable, high-value items
CDD in Practice: Common Scenarios
Scenario 1: Walk-in Cash Purchase
A customer walks in and wants to buy a $15,000 gold chain, paying cash.
You must:
- Collect and verify their ID (photo ID + secondary document)
- Record the transaction details
- File a TTR within 10 business days (cash ≥ $10,000)
- Assess whether anything is suspicious
- If suspicious, file an SMR within 3 business days
Scenario 2: Trade Customer Selling Scrap Gold
A regular trade customer brings in $25,000 worth of scrap gold for purchase.
You must:
- Verify their identity (if not already done)
- Confirm the source of the gold — is it from their business? Inherited? Other?
- Record the transaction
- File a TTR if paying cash
- Be alert for signs of stolen goods or proceeds of crime
Scenario 3: Online Purchase with Bank Transfer
A customer orders a $12,000 diamond engagement ring online and pays by bank transfer.
You must:
- Verify their identity before completing the sale
- Record the transaction
- No TTR required (not a cash transaction)
- Still assess for suspicious indicators
Scenario 4: Repeat Customer with Escalating Purchases
A customer who previously bought a $5,000 bracelet returns weekly, buying increasingly expensive items — now at $20,000 per visit, always in cash.
You must:
- Recognise the pattern as a potential red flag
- Apply enhanced due diligence — ask about the source of funds
- File TTRs for each cash transaction ≥ $10,000
- Seriously consider filing an SMR — the escalating pattern is itself suspicious
- Document your assessment and reasoning
How to Build Your Program in Practice
Step 1: Appoint a Compliance Officer (Week 1)
This should be the business owner or a senior manager. For sole traders, it's you. The compliance officer is responsible for:
- Maintaining the AML/CTF program
- Ensuring staff are trained
- Filing reports with AUSTRAC
- Being the point of contact for AUSTRAC
Step 2: Complete Your Risk Assessment (Week 1–2)
Assess the ML/TF risks specific to your business:
| Risk Factor | Higher Risk | Lower Risk |
|---|---|---|
| Customer type | Walk-in cash buyers, trade buyers | Known repeat customers with verified ID |
| Product type | Bullion, uncut stones, scrap gold | Finished retail jewellery |
| Transaction size | Greater than $50,000 | Less than $10,000 |
| Payment method | Cash | Bank transfer, credit card |
| Geography | Customers from FATF high-risk countries | Local customers |
| Channel | In-person, no prior relationship | Established business relationship |
Step 3: Write Your AML/CTF Program (Week 2–3)
Use AUSTRAC's jeweller starter kit as your foundation. AML Mate generates a complete Parts A–F program pre-filled for your business — typically in 15 minutes.
Step 4: Train Your Staff (Week 3–4)
Everyone who handles designated services needs training on:
- How to identify customers and verify their ID
- Red flags to watch for
- How to escalate suspicious transactions
- The importance of not tipping off customers
- Record keeping requirements
Training must be completed within 30 days of an employee starting designated service work.
Step 5: Set Up Your Systems (Week 4)
You need practical systems for:
- Recording customer identification
- Storing copies of ID documents
- Tracking transactions at or above $10,000
- Filing SMRs and TTRs with AUSTRAC
- Screening customers against the DFAT sanctions list
Step 6: Enrol with AUSTRAC (Now)
Don't leave this for July. Enrol today at AUSTRAC Online.
Transitional Rules for Existing Customers
You don't need to verify every existing customer's identity on 1 July 2026. Transitional rules allow:
- Existing ongoing customers: You have 12 months (until 1 July 2027) to complete CDD on existing customers you had before 1 July 2026
- New customers from 1 July 2026: Full CDD must be completed before providing the designated service
- Priority: Focus first on higher-risk customers — large cash buyers, trade customers, those you know less about
Penalties for Non-Compliance
AUSTRAC's enforcement powers are real:
- Failure to have an AML/CTF program: Up to $31.3 million (body corporate)
- Failure to conduct CDD: Up to $31.3 million
- Failure to file SMRs: Up to $31.3 million
- Tipping off: Criminal offence — imprisonment
- Failure to enrol: Daily penalties until resolved
AUSTRAC has stated it will take a pragmatic approach to Tranche 2 enforcement — but having no program at all and making no effort will attract the strongest response.
The Bottom Line
AML/CTF compliance for jewellers is manageable. The $10,000 threshold means most retail sales won't trigger CDD requirements. But for high-value transactions — particularly those involving cash, bullion, or trade customers — you need proper systems in place.
Start now. Enrol with AUSTRAC, build your program, train your staff, and get your record-keeping systems ready. 79 days isn't a lot of time, but it's enough if you act today.
Need help getting compliant? AML Mate is built specifically for Tranche 2 businesses. Generate your AML/CTF program, manage client CDD, screen against sanctions lists, and file reports — all from one platform. Start your 14-day free trial or run a free compliance check to see where you stand.