AML compliance for precious metals, stones and products

Since 1 July 2026, buying or selling precious metals, precious stones or precious products in the course of carrying on a business can be a designated service under Australia's anti-money laundering and counter-terrorism financing regime. Coverage depends on three things together: the goods are regulated items, the regulated items total at least A$10,000, and payment is made in physical currency, virtual assets or a combination of both.

A high sale price alone does not create the obligation, and neither does trading in valuable goods generally. A business should assess each transaction against all three elements and record the result. AUSTRAC's national risk assessment work identifies high-value goods as attractive for laundering because they hold value, are recognised internationally and can be moved or resold easily.

What the regulated goods categories cover

Precious metals include gold, silver, platinum, iridium, osmium, palladium, rhodium and ruthenium, together with alloys containing a prescribed minimum proportion of those metals. Precious stones are substances of gem quality recognised for their beauty, rarity and value, including diamond, corundum, beryl, garnet, jadeite jade, opal, pearl and topaz. Precious products are items made of, containing or having attached to them any regulated precious metal or stone, whether manufactured or unmanufactured, and can include jewellery and watches.

Classification should follow the current definitions rather than trade shorthand. A single item can contain regulated and unregulated components, and a mixed sale can combine regulated goods with services or other stock. The business should be able to show how it valued the regulated items when it applied the threshold.

The A$10,000 payment test and linked transactions

The threshold can be met by one transaction or by transactions that are linked or appear to be linked. Instalments toward a single purchase, a series of purchases with a common purpose, and sales divided across branches, days, sales staff or apparently related customers can all require aggregation.

Physical currency means cash such as Australian or foreign banknotes and coins. Virtual assets are treated as a qualifying payment method for this designated service. A sale paid only by debit card, credit card or bank transfer does not satisfy the payment-method test, although the business should still consider whether another designated service applies.

Practical systems matter here. Point-of-sale, layby, deposit, trade-in and online records should connect payments to the underlying purchase so the business can identify when linked activity reaches the threshold. Staff should not be left to make that assessment from memory.

Bullion dealing is a separate designated service

Buying and selling bullion in the course of carrying on a bullion-dealing business has been a designated service for several years and continues after the 2026 reforms. It carries its own initial customer due diligence point, which applies at A$5,000 retail value, and it is not limited to physical-currency or virtual-asset payments.

A dealer can therefore be covered by the established bullion service, the newer precious-goods service, or both. Keeping the two frameworks distinct avoids confusing the A$5,000 bullion CDD point with the A$10,000 precious-goods threshold. The bullion dealer guidance sets out that classification in more detail.

Enrolment, program and governance

Enrolment is completed through the AUSTRAC Business Profiles Portal, which opened on 31 March 2026. A business already providing the designated service at commencement was required to enrol by 29 July 2026, and a business starting later must generally apply no later than 28 days after it first provides the service.

The AML/CTF program should rest on a documented assessment of money laundering, terrorism financing and proliferation financing risk covering customer types, goods, sales and buying channels, countries, payment methods and delivery arrangements. It should be approved at senior level and be proportionate to the size, nature and complexity of the business. The business must appoint an AML/CTF compliance officer who meets the applicable eligibility requirements and has the authority, access and resources to perform the role.

Customer due diligence and enhanced measures

Initial customer due diligence should ordinarily be completed before the business provides the designated service. That means identifying the customer, verifying identity from reliable and independent information, understanding the purpose and intended nature of the dealing and identifying beneficial owners where the customer is a company, trust, partnership or other entity.

Screening should address politically exposed person status and applicable sanctions in line with the business's procedures, with human review of any possible match. Enhanced measures apply where a statutory trigger or the risk assessment requires them, and can include further identity evidence, ownership explanations, source of funds or source of wealth enquiries, senior approval and closer monitoring.

Monitoring indicators for a goods business

Monitoring should compare activity with what the business knows about the customer and the transaction. Circumstances that warrant examination can include:

• Payments structured just below A$10,000, or spread across branches, days or apparently connected buyers.
• A customer who shows unusual interest in identification requirements or reporting thresholds.
• A third party paying for or collecting goods without a clear explanation, or a delivery address that does not fit the customer profile.
• Purchases inconsistent with the customer's apparent means, or rapid resale at a material loss.
• Little interest in price, quality, certification or provenance, or misstated weight, quality or origin.
• Unexplained cross-border movement of goods, funds or virtual assets.

An indicator is a prompt for enquiry rather than a conclusion. The file should record the question asked, the information obtained and the effect on the risk assessment.

Reports and records

A threshold transaction report concerns a statutory transfer of A$10,000 or more in physical currency while providing a designated service. That test is separate from the precious-goods threshold: a virtual-asset payment can bring the sale within the designated service without meeting the physical-currency TTR trigger.

If the business forms reasonable grounds for suspicion under the Act, it must submit a suspicious matter report within the applicable period. The usual period is 24 hours for a terrorism financing suspicion and three business days for other reportable suspicions. Information about a report must be handled in accordance with the tipping-off restrictions.

Records should connect goods classification, customer identity, beneficial ownership, risk rating, payment method, delivery, monitoring reviews, enhanced measures and reporting decisions. Many customer, transaction and program records require retention for seven years, with the starting point depending on the record type.