AML/CTF Tranche II for Precious Metals & Stone Dealers

Are You In Scope? The $10,000 Threshold Rule

For dealers in precious metals, stones, and products, the AML/CTF designated service is specifically tied to the method and value of payment. The rule is precise and applies regardless of business size:

You are a reporting entity if you buy or sell precious metals, precious stones, or precious products — in the course of carrying on a business — and the buyer or seller makes or receives payment of $10,000 or more in physical cash, virtual assets (cryptocurrency), or a combination of both, in a single transaction or across multiple linked or apparently linked transactions.

What Is Covered — Definitions

Precious metals include gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium, and any alloy containing at least 2% by weight of any of these substances, in manufactured or unmanufactured form.

Precious stones include substances of gem quality with recognised beauty, rarity, and commercial value — including beryl, corundum, diamond, garnet, jadeite jade, opal, pearl, and topaz.

Precious products are items made from or incorporating precious metals or stones — including jewellery, watches, and high-value goods containing precious materials.

The Linked Transaction Rule — Critical for Retailers

The $10,000 threshold applies across linked and apparently linked transactions, not only to individual transactions. Transactions are considered linked where:

A customer makes multiple payments under a single invoice
A single payment is made for multiple invoices on the same date
A single item worth $10,000 or more is paid in instalments across multiple days
A customer’s behaviour suggests deliberate structuring — splitting a larger transaction into smaller amounts to stay below the threshold

Worked example: A customer purchases a gold watch for $15,000 and pays in three cash instalments of $5,000. All three are linked transactions. The $10,000 threshold is met when the cumulative value reaches $10,000 — AML/CTF obligations apply from that point. Deliberately structuring payments to stay below $10,000 is a separate criminal offence.

How to Stay Out of Scope: The No-Cash Policy Strategy

Precious metals dealers that make a clear, documented, and consistently enforced decision not to accept cash or virtual asset payments of $10,000 or more are not providing a designated service and are therefore not reporting entities. This is a legitimate compliance strategy — but it must be genuine. A written policy, communicated to all staff, enforced at point of sale, and evidenced in your records is required. Accepting even a single qualifying payment inadvertently brings you into scope.

Your Core Obligations from 1 July 2026

Obligation	What It Means for Your Business
Enrol with AUSTRAC	Register via the AUSTRAC Business Portal from 31 March 2026. Deadline: 29 July 2026.
ML/TF Risk Assessment	Identify and document your money laundering and terrorism financing risks — tailored to your clients, services, and geographies.
AML/CTF Program	A written, risk-based compliance program covering your policies, procedures, controls, and staff training obligations.
Customer Due Diligence (CDD)	Identify and verify every client before providing a designated service. Enhanced checks required for high-risk clients and Politically Exposed Persons (PEPs).
Ongoing Monitoring	Continuously monitor client relationships and transactions for suspicious activity throughout the engagement.
Suspicious Matter Reporting	File Suspicious Matter Reports (SMRs) with AUSTRAC promptly when required. Failure to report is a serious criminal offence.
Record Keeping	Retain identity verification and transaction records for a minimum of seven years.
Appoint a Compliance Officer	Designate a qualified AML/CTF compliance officer and notify AUSTRAC by 29 July 2026.

Key Dates

Date	Milestone
31 March 2026	AUSTRAC enrolment portal opens for Tranche II entities.
1 July 2026	All AML/CTF obligations commence. Your program must be fully operational from this date.
29 July 2026	Final deadline to complete AUSTRAC enrolment and notify your nominated compliance officer.

Why Precious Metals Are a High-Risk Sector for Financial Crime

AUSTRAC’s National Risk Assessment specifically identified high-value goods — including jewellery, watches, and precious metals — as vehicles regularly encountered in domestic money laundering investigations. Key risk characteristics include:

High value relative to size and weight — easy to transport, conceal, and move across borders
Internationally recognised and highly liquid — can be converted to cash quickly in multiple markets
Cash transactions historically difficult to trace or attribute
Beneficial ownership of goods is rarely recorded at point of sale
Susceptibility to invoice manipulation and over or under-valuation

Australia is now aligning with the UK, EU, and US — where precious metals and high-value goods dealers have been subject to AML/CTF obligations for years.

Why WilliamThomas&Co.?

Why precious metals and jewellery businesses choose WilliamThomas&Co.

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Regulatory Expertise — Former financial services compliance specialists. We know what AUSTRAC actually expects — not just what the legislation says.

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End-to-End Service — From scoping and risk assessment through to program development, AUSTRAC enrolment, and staff training. We handle it all.

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Tailored, Not Templated — Your AML/CTF program is built for your business, your clients, and your risk profile. Not a copy-paste document.

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Ongoing Partnership — Compliance doesn’t stop at 1 July 2026. We offer annual reviews, regulatory update briefings, and on-call advisory support.

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AUSTRAC Engagement Support — If AUSTRAC comes knocking, we’re in your corner. We support regulatory enquiries, audits, and remediation.

Our Tranche II Services for Precious Metals & Stone Dealers

Scope and threshold assessment — determine whether and when your business crosses the $10,000 reporting threshold
No-cash policy design — documented, enforceable policies to manage threshold risk and stay out of scope
ML/TF Risk Assessment — tailored to your product lines, customer base, and transaction types
AML/CTF Program development — practical compliance program built for retail and wholesale precious goods businesses
AUSTRAC enrolment support — guidance through the Business Portal from day one
CDD system design — identity verification processes that work at point of sale
Staff training — frontline training for sales staff on threshold identification, CDD, and suspicious matter recognition
Structuring awareness training — recognising and responding to suspected structuring behaviour

AML/CTF Compliance for Precious Metals, Stones & Products Dealers