Two different threshold tests
The same $10,000 figure answers two different questions. Keep these decisions separate at the counter and in your procedures.
1. Is the service regulated?
For the precious items service, count cash and virtual assets together, including transactions that are linked or appear linked. At least $10,000 for regulated items can bring the service into scope. The service also needs a geographical link to Australia.
2. Is a TTR required?
Check each physical currency payment. A payment of at least $10,000 in connection with a designated service triggers the TTR requirement. Do not combine separate instalments for this test. Virtual asset payments are not physical currency.
Example: one bracelet, five payments
A $20,000 bracelet paid for in five linked $4,000 cash instalments can be a regulated service. None of those separate payments reaches the TTR threshold. If the facts give reasonable grounds to suspect structuring, consider the separate SMR obligation. Ordinary instalments are not automatically suspicious.
Which transactions trigger obligations?
Card or bank transfer only
A purchase paid only by debit card, credit card or bank transfer does not trigger this precious items designated service. Check separately for other services such as bullion dealing or lending.
Cash or virtual assets below $10,000
A per-payment cap alone is not enough. Detect transactions that are linked or appear linked and could reach $10,000. Consider the same underlying sale, instalment arrangement, purpose, invoice and transaction history.
Regulated payments accepted
Prepare your program and customer checks before accepting regulated transactions. Apply your policy to both purchases from customers and sales to customers. Explain permitted payment methods and escalation steps to staff.
Why jewellers are regulated
Precious items are portable stores of value and can be resold. The identity of the customer, funding and transaction pattern help explain the risk.
Behaviour at the counter
Enquiries about avoiding reporting, unexplained third-party payments or reluctance to answer reasonable questions may warrant enquiries. Record the circumstances instead of treating one behaviour as proof.
Patterns across visits
Look for related payments, multiple people paying for one purchase, unusual resale requests and payment splitting that appears intended to avoid reporting. Assess reasonable grounds for suspicion and escalate promptly.
Turn the policy into a working process
Enrol and assign responsibility
Businesses already providing newly regulated services had to enrol by 29 July 2026. A new provider generally applies within 28 days after the day it starts providing a designated service. Appoint an eligible compliance officer, record their authority and notify AUSTRAC within the applicable period.
Put your program into practice
Before providing designated services, establish an AML/CTF program that addresses your risks. Document your risk assessment and policies, obtain senior manager approval, train staff and set review and independent evaluation arrangements. Templates need to be customised and used in daily work.
Check the customer and keep monitoring
Generally complete initial CDD before the designated service. Establish identity, authority, relevant beneficial owners, purpose and risk. Apply enhanced CDD where its triggers apply and keep monitoring the relationship and payments.
Give staff an escalation route
Record each payment against the customer and purchase so linked activity is visible. Define who reviews an exception, what evidence to record and how to assess reporting. A software record does not replace a decision by your business.
Can you use the jeweller starter kit?
Check more than your staff count
The starter kit is designed for a defined jewellery business profile, including 15 or fewer personnel, only the relevant cash-based precious items service, no virtual asset payments and further customer, operating and group conditions. It is designed for regulated cash transactions with individual customers. Check every criterion and adapt your program where your business differs.
A payment policy needs controls
Refusing regulated cash and virtual asset transactions may keep this service out of scope, but only if the policy works in practice, including linked payments. Other designated services can still create obligations. Keep evidence of your scope assessment.
Report the right matter at the right time
SMR: suspicion, not a dollar threshold
Where the SMR obligation arises, report terrorism financing suspicions within 24 hours of forming the suspicion. For other suspicions, report within 3 business days after the day the suspicion forms. Special legal professional privilege rules can apply; check the SMR guide. An unusual transaction alone does not establish reasonable grounds for suspicion.
TTR: a physical currency payment
Report a physical currency transaction of AUD $10,000 or more (or its foreign currency equivalent) made in connection with a designated service within 10 business days after the day it occurs. Card payments, bank transfers and virtual assets are not physical currency. Do not add separate instalments together to create a TTR threshold.
Keep the record of what happened
Record checks, decisions, monitoring and reports under the applicable retention rules. Keep required identity information and verification records; the law does not require retaining copies of identity documents. AML Mate prepares report records and does not submit reports to AUSTRAC. Lodge in AUSTRAC Online and keep your receipt and reference.
Frequently asked questions
Do jewellers need AML/CTF compliance in Australia?
It depends on the services and payments. The precious items service covers buying or selling regulated items for at least $10,000 in cash or virtual assets, including linked transactions, with a geographical link to Australia. Other designated services must be assessed separately.
What is the $10,000 threshold for jewellers?
For service coverage, cash and virtual assets are combined across linked or apparently linked transactions for regulated items. For TTR reporting, test each physical currency payment separately. The two tests are different.
Can jewellers use a simplified AML/CTF program?
The AUSTRAC jeweller starter kit is designed for businesses meeting a specific profile. Fifteen or fewer personnel is only one criterion. Check service, payment, customer and operating conditions, customise the documents and implement the program.
What are red flags for money laundering in the jewellery industry?
Examples include unexplained third-party payments, requests to avoid reporting, unclear funding and payment splitting that appears intended to evade reporting. Investigate in context and assess whether reasonable grounds for suspicion exist.
I only accept card payments - do I need to comply?
Card-only purchases do not trigger the precious items designated service. Check all the services your business provides, including any bullion dealing or lending, before concluding the business has no AML/CTF obligations.
What counts as a linked transaction?
Consider connections such as the same underlying sale, payment arrangement, purpose, invoice or customer transaction pattern. Linked transactions can be legitimate. Linkage for service coverage does not automatically create a TTR or establish suspicion.
Do I need to report every $10,000 cash sale?
A physical currency payment of AUD $10,000 or more, or the foreign currency equivalent, in connection with a designated service requires a TTR within 10 business days after the day it occurs. Separate cash instalments are not added together for this reporting threshold.
Resources and sources
Official guidance checked on 14 October 2026. Follow the source for the full conditions and exceptions.