AML Software for Jewellers & Bullion Dealers

From 1 July 2026, dealers in precious metals, stones and products are reporting entities

Under the amended AML/CTF Act 2006 and the AUSTRAC Tranche 2 reforms, Australian businesses that buy or sell precious metals, stones or products provide a designated service when specific conditions are met. From 1 July 2026 you must enrol with AUSTRAC, run a written AML/CTF program, screen customers against the DFAT sanctions list, lodge suspicious matter reports, and keep records for 7 years.

The trigger is specific — AUSTRAC states the designated service applies when the transaction is valued at $10,000 or greater and involves a single payment (or linked payments) of physical currency or virtual assets. If the purchase or sale is paid entirely by debit or credit card or bank transfer, the business is not providing a designated service.

AMLTranche handles the threshold logic, the currency constraint, and the CDD workflow automatically — so a jeweller or bullion dealer doesn't need to eyeball every transaction for whether AUSTRAC rules apply. Bullion dealers are already a Tranche 1 reporting entity category; Tranche 2 brings in a broader set of DPMSPs (dealers in precious metals, stones and products) from 1 July 2026.

Built for over-the-counter sales, bullion transactions and the $10,000 threshold

Jewellers and bullion dealers need compliance that flags when a transaction crosses the AUSTRAC threshold and triggers CDD — and equally, doesn't waste staff time on transactions that don't. AMLTranche automates this logic.

Five common transactions a jeweller or bullion dealer sees, and what AUSTRAC requires for each

Most AML training treats customer due diligence as a single tick-box. In practice, the work changes a lot depending on whether you are selling at the counter, buying scrap, accepting a trade-in, or shipping overseas. Five scenarios most Australian dealers in precious metals and stones encounter regularly, and how the obligations apply to each.

1. Single cash sale over $10,000

A familiar customer buys a 1kg silver bar for around $1,250 in cash. No issue. The next week an unfamiliar customer wants to buy a 100g gold bar for around $11,800 in cash. This crosses the AUSTRAC threshold transaction reporting boundary and triggers two parallel obligations: customer due diligence on the buyer, and a Threshold Transaction Report lodged with AUSTRAC within 10 business days.

What CDD looks like at the counter:

• Government-issued photo identification (Australian driver licence, passport, or proof-of-age card)
• Verification of name, date of birth, and residential address
• DFAT and PEP screening before completing the sale
• Source of funds confirmation. Cash from a recent property sale, an inheritance, or a bank withdrawal each carries a different risk profile

Cash-only at this threshold is not unlawful, but it is one of AUSTRAC's listed indicators of higher money-laundering risk. The dealer is not required to refuse a legitimate transaction, but the documented justification for proceeding, the CDD record, and the TTR submitted afterwards are what an AUSTRAC examination years later will look for. AMLTranche captures the customer record, runs sanctions and PEP screening, and stores the supporting evidence in the audit log so the operator can complete the TTR with all the relevant facts on hand.

2. Buying scrap gold or jewellery from a member of the public

A member of the public walks in with their grandmother's old gold jewellery, around 80 grams, and wants to sell it for cash. The dealer is providing a designated service, but in this transaction the dealer is the buyer, not the seller. CDD applies to the customer who is selling the goods.

What changes when the dealer is the buyer:

• The dealer still verifies the customer's identity at standard CDD level
• Source of the goods, not just source of funds, becomes the relevant question. Inherited from a deceased estate, family heirloom, or recent purchase each need brief documentation
• Higher-risk indicators include large volumes of newly acquired items, multiple visits aggregating large cash payouts, items still in original retail packaging, or stamps and engravings that have been removed
• DFAT and PEP screening still runs on the seller

If the cumulative payout to a single seller crosses the $10,000 threshold across linked transactions, structuring rules apply and the dealer cannot split the transactions to stay below the limit. The dealer needs a documented process for recognising returning sellers and tracking aggregated payouts. AMLTranche stores each seller as a single customer record with a transaction history attached, so the operator can see prior payouts before completing the next one.

3. Linked sub-threshold cash purchases by the same customer

A returning customer comes in three Saturdays in a row. First visit, $7,500 cash for a gold chain. Second visit, $8,200 cash for a ring. Third visit, $9,000 cash for a watch. No single transaction crosses the $10,000 threshold. None individually triggers a Threshold Transaction Report.

Viewed together, the pattern is what AUSTRAC calls structuring. Three cash purchases by the same customer over three weeks total $24,700, all sized just below the threshold. Structuring is an offence under the AML/CTF Act, and the pattern itself is a strong indicator for a Suspicious Matter Report regardless of any single TTR.

What the dealer needs to do:

• Recognise the customer across multiple visits, not treat each visit as a separate first-time encounter
• Hold a single customer record with the cash payments aggregated against it
• Form a view on whether the pattern is innocent (for example, separate gift purchases for different family members with a valid explanation) or warrants escalation
• Lodge an SMR where the pattern raises a reasonable suspicion of money laundering or structuring, even if no single transaction is reportable

AMLTranche stores each customer as a single record with the full transaction history attached, so the operator can see prior cash payments before completing the next one. The decision to escalate or proceed is an operator judgment, but the historical record is on hand to support that judgment and the audit trail captures it.

4. Trade-in where the dealer pays out cash above the threshold

A customer brings in old gold jewellery valued at $14,000. They want to apply $2,000 of that value against a new $2,000 piece of equivalent design, with the dealer paying out the $12,000 difference in physical cash on the spot. The transaction triggers CDD because the dealer is paying out more than $10,000 in physical currency to the customer.

What this looks like in practice:

• One CDD record covers the customer for both legs of the trade
• Identification verified at standard CDD level
• DFAT and PEP screening run on the customer
• Source of the old gold (heirloom, inheritance, prior purchase) documented
• Threshold Transaction Report lodged because the cash payout crosses $10,000

The trap with trade-ins is treating them as a single transaction value and missing the direction of the cash flow. When the dealer is the cash payer, the same threshold logic applies, just from the opposite side of the counter. AMLTranche records both legs of the trade against a single customer file, with the cash payout amount captured so the operator can apply the threshold rule on the right number.

These four scenarios cover the bulk of day-to-day compliance work for an Australian jeweller or dealer in precious metals and stones. Specialist transactions like coin auctions, refining services, and inter-dealer wholesale trades follow similar patterns with their own variations. The common thread is that the AML/CTF obligations attach to physical-currency transactions at or above $10,000, including linked transactions and cash payouts in either direction. Software that captures the customer history and the cash flow against a single record saves the operator from rebuilding the picture from memory at the counter.