Why are jewellers now regulated?
AUSTRAC's money laundering national risk assessment found that the retail jewellery sector poses a high money laundering risk in Australia. Dealers in precious stones and metals are among the most at risk of being used for money laundering. Australian criminals — from low-level to sophisticated — are regularly found with jewellery and luxury watches containing precious stones and metals, especially diamonds.
Precious stones and metals are attractive to criminals because they can be:
- Bought and sold readily and anonymously using cash
- Easy to conceal and move domestically or offshore
- Difficult to trace or detect once reshaped or remodelled
- Easy to convert back to legitimate funds
- Under- or over-valued to disguise the true amount being laundered
- Bought without having to prove ownership
The Tranche 2 reforms bring Australia in line with international AML standards. This doesn't mean your customers are criminals — it means you need basic systems to identify and report suspicious activity when handling large cash transactions.
Which transactions trigger obligations?
Your AML obligations are triggered when you accept physical currency (cash) or virtual assets of $10,000 or more — either in a single transaction or in linked transactions — for the sale or purchase of precious stones, metals, or precious products.
Precious products include jewellery, watches, and other objects containing or made from precious metals or stones — including goldsmith and silversmith wares, ornaments, and personal adornments.
Important: “Linked transactions” are multiple separate transactions that together total $10,000 or more. For example, a customer who buys a $6,000 necklace one day and a $5,000 bracelet the next day has made linked transactions totalling $11,000. You must monitor for this.
What if I don't accept cash above $10,000?
If your business does not accept physical currency or virtual assets of $10,000 or more — for example, you only accept card payments or bank transfers — then you are not required to have an AML/CTF program for precious metals/stones services. However, you must have a clear documented policy stating this and monitor for customers attempting to structure transactions to avoid the threshold.
What you need to do
Step 1: Decide your payment policy
The simplest way to manage your AML obligations is to set a clear policy on cash acceptance. AUSTRAC has outlined several options:
- Option A: Don't accept cash or virtual assets at all — no AML/CTF program needed for precious metals/stones services
- Option B: Accept cash under $10,000 only — no AML/CTF program needed, but you must monitor for linked transactions and structuring
- Option C: Accept cash of $10,000+ from individual Australian customers only — use AUSTRAC's streamlined compliance process
- Option D: Accept cash of $10,000+ from all customer types — full AML/CTF program required
Most small jewellery businesses can use Option B or C, significantly reducing their compliance burden.
Step 2: Register with AUSTRAC
If your business accepts cash or virtual assets of $10,000 or more, you must register with AUSTRAC by 29 July 2026. Registration is free and done online. Enrolment opens 31 March 2026.
Step 3: Appoint an AML/CTF compliance officer
Designate an AML/CTF compliance officer — typically the store manager or business owner for small businesses. This person oversees your AML/CTF program and ensures staff are trained.
Step 4: Create your AML/CTF program
AUSTRAC provides a Starter Kit specifically for jewellers with 15 or fewer personnel. If you primarily deal with individual Australian customers paying with physical currency (not virtual assets), you can use the streamlined compliance process.
Your program must cover risk assessment, customer identification procedures, transaction monitoring (including watching for structuring and linked transactions), and staff training.
AML Mate automates this. Answer questions about your business and we generate a tailored AML/CTF program using AUSTRAC's official templates.
Step 5: Implement Customer Due Diligence (CDD)
Before completing a transaction of $10,000 or more in cash, you must verify your customer's identity with government-issued photo ID. For low- and medium-risk individual customers using physical currency, AUSTRAC provides a streamlined CDD process.
Higher-risk customers — including those from high-risk jurisdictions, PEPs, and companies or trusts where beneficial ownership is unclear — require Enhanced Due Diligence.
Step 6: Know your reporting obligations
As a reporting entity, you must file:
- Threshold Transaction Reports (TTRs) — within 10 business days for any cash transaction of $10,000 or more
- Suspicious Matter Reports (SMRs) — within 24 hours if terrorism financing related, or within 3 business days for money laundering or other suspicious matters
Common red flags for jewellers
Based on AUSTRAC guidance, watch for these suspicious activity indicators:
Customer behaviour
- Customer uses large amounts of cash to purchase precious stones or metals and refuses to provide identification
- Customer makes multiple purchases just below the $10,000 reporting threshold (suspected structuring)
- Customer quickly sells products back or re-sells at a loss — a common technique for converting cash to “clean” funds
- Customer seeks unusual anonymity or avoids KYC processes
- Customer uses a third party in transactions with no clear reason
Unusual patterns
- Customer doesn't appear to understand or have experience with precious metals — they are buying to store value, not for personal use
- Customer from a high-risk jurisdiction making large purchases
- Customer has a long-term relationship but frequently changes bank details, addresses, or business names between transactions
- Transactions don't match the customer's profile — for example, a small sole trader making $50,000 purchases
Structuring
Structuring is a criminal offence. It occurs when a customer deliberately splits a $10,000+ transaction into smaller amounts to avoid reporting thresholds. If you suspect structuring, you must file an SMR — even though individual transactions are below the threshold. Common patterns include a customer visiting your store on consecutive days, each time purchasing just under $10,000 in cash.
Simplified compliance options
AUSTRAC recognises that many jewellers are small businesses. The compliance framework includes several ways to reduce your burden:
- Refuse cash above $10,000 — eliminates AML/CTF program requirement entirely
- Streamlined CDD — for low/medium-risk individual customers using physical currency, a simplified identity verification process is available
- Starter Kit — AUSTRAC's template-based approach for businesses with 15 or fewer staff, designed to be customised rather than written from scratch
How AML Mate helps
- AI-generated AML/CTF program — tailored to your jewellery business using AUSTRAC's official Starter Kit
- Transaction tracking — monitors for linked transactions and structuring patterns
- Customer ID management — streamlined CDD process with automated risk scoring
- TTR & SMR reporting — smart pre-fill with step-by-step wizards and deadline tracking
- Staff training — built-in modules covering suspicious activity identification and reporting obligations
Frequently asked questions
“I only accept card payments — do I need to comply?”
If you never accept cash or virtual assets of $10,000 or more, you do not need an AML/CTF program for precious metals/stones services. But you should document this policy clearly and ensure staff follow it consistently. If you provide other designated services (such as bullion sales or loans), those may still trigger obligations.
“What counts as a linked transaction?”
Linked transactions are multiple separate transactions that together total $10,000 or more. This includes a customer making several purchases over a short period. If you suspect transactions are being split to avoid the threshold, that is structuring — a criminal offence — and you must file an SMR.
“Do I need to report every $10,000 cash sale?”
Yes. Every cash transaction of $10,000 or more requires a Threshold Transaction Report (TTR) filed with AUSTRAC within 10 business days. This is a legal obligation with penalties of up to 100,000 penalty units for non-compliance.