AML/CTF requirements for Australian bullion dealers

Businesses that buy or sell bullion have been covered by Australia's anti-money laundering and counter-terrorism financing regime for years. That established bullion designated service continues after the reforms that commenced on 1 July 2026. The reforms also introduced a separate designated service for certain purchases and sales of precious metals, precious stones and precious products.

A dealer may need to apply both frameworks to the same transaction. The product, business capacity, value and payment method determine which rules are engaged. Clear classification avoids mixing the A$5,000 bullion customer due diligence point with two separate A$10,000 concepts: the precious-goods designated-service threshold and the physical-currency transfer threshold for a TTR.

The established designated service for bullion dealing

A business provides the bullion designated service when it buys or sells bullion while carrying on a bullion-dealing business. A purchase from a non-retail customer, including a bullion wholesaler, can also be covered. The category can apply to precious metal traders, refiners, jewellers, coin dealers and pawn brokers when their activities meet the legal test.

A private purchase or sale outside the course of carrying on a bullion business does not provide this designated service. The assessment should examine the seller's or buyer's actual activity, including commercial organisation, frequency, records, advertising and purpose. An isolated transaction can still occur in the course of a business.

AUSTRAC guidance describes bullion as gold, silver, platinum or palladium authenticated to a specified quality and fineness and valued according to the market price of its precious-metal content. Forms can include bars, ingots, plates, wafers, similar mass forms and coins. A coin traded by reference to its bullion value can qualify, while a coin priced for collectability or another characteristic needs separate classification.

Physical delivery is unnecessary for a bullion purchase or sale. A dealer may retain the purchased metal in storage or account for a customer's interest in a pool. In that situation, the buying or selling activity remains the focus of the bullion designated service. Storage, by itself, should not be described as an independent bullion designated service without a separate legal basis.

The A$5,000 point for initial bullion CDD

Current AUSTRAC guidance exempts initial customer due diligence only when the bullion's retail value is below A$5,000 and enhanced CDD is not required. Initial CDD applies at A$5,000 or more. Enhanced CDD removes the exemption even at a lower value.

This point concerns CDD for the established bullion service. It does not replace the need to assess behaviour. Related activity divided among associates or branches below A$5,000 can require review.

The separate 2026 service for precious metals, stones and products

From 1 July 2026, a separate designated service can apply when a business buys or sells regulated precious metals, stones or products. The items must total at least A$10,000, with payment in physical currency, virtual assets or both. Single transactions and linked or apparently linked transactions count.

Physical currency means cash such as Australian or foreign banknotes and coins. Debit card, credit card and bank-transfer payments do not satisfy this payment-method test. A bullion purchase paid by bank transfer can still fall under the established bullion service.

Dealers accepting physical currency or virtual assets need systems that connect instalments by customer, product, invoice, underlying purchase, common purpose and timing. Split payments among people, branches or days require examination.

The A$10,000 physical-currency transfer test for TTRs

A threshold transaction report concerns a statutory transfer of A$10,000 or more in physical currency. The separate precious-goods threshold can be met by physical currency, virtual assets or both.

A sale paid wholly by bank transfer does not meet the physical-currency TTR trigger. Virtual assets can meet the precious-goods test, but they do not meet the TTR test. A dealer party to a reportable physical-currency transfer should lodge the TTR within the statutory timeframe and retain supporting details.

CDD for individuals, entities and beneficial owners

CDD begins by identifying the customer and verifying identity using reliable and independent information. For a company, trust, partnership or other entity, the dealer should establish its legal existence, ownership and control, identify beneficial owners and verify the required persons. The dealer should also understand the purpose and intended nature of the relationship.

The customer profile can cover expected purchase or sale volumes, products, payment methods, delivery locations, storage instructions and use of third parties. Screening should address politically exposed person status and applicable sanctions in accordance with the dealer's procedures. A possible match needs documented escalation and resolution.

Source of funds and source of wealth checks should be used where required by enhanced CDD or the assessed risk. Relevant circumstances can include substantial unexplained cash, activity outside the customer's apparent means, opaque corporate ownership, third-party payment, rapid movement of value or exposure to a higher-risk jurisdiction. The evidence sought should be proportionate and capable of supporting the dealer's conclusion.

Risk assessment and practical monitoring

The dealer's AML/CTF risk assessment should address customer types, products, sales and purchasing channels, countries, payment methods and delivery arrangements. It should distinguish retail customers, trade counterparties, refining customers and suppliers where their risks differ. Online sales, remote verification, cross-border movement, high-value cash, virtual assets and third-party collection can require tailored controls.

Transaction monitoring should combine customer and transaction information across stores and systems. Useful data includes identity, beneficial ownership, product description, weight, quality, price, payment method, payer, delivery address, staff member, branch and time. Monitoring rules should produce a review rather than an automatic conclusion.

Indicators that warrant examination can include:

• A customer refuses identification, provides inconsistent information or focuses on reporting and identification thresholds.
• Payments are divided below A$5,000 or A$10,000, spread across branches or made by apparently connected people.
• A third party pays for or collects bullion without a clear explanation, or the delivery location differs unexpectedly from the customer profile.
• The customer buys and resells bullion quickly at a loss, makes purchases inconsistent with their known means or shows little interest in price and fees.
• The transaction misstates weight, quality, metal type, price, quantity or origin, or uses an unnecessarily complex ownership or payment chain.

SMRs, enhanced measures and records

An indicator should prompt examination in context. If the dealer forms reasonable grounds to suspect a matter covered by 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. The dealer must also protect the report from tipping off.

If the dealer proposes to continue the relationship after a relevant suspicion or another enhanced CDD trigger, additional measures may be required. These can include further verification, ownership checks, source enquiries, senior approval and closer monitoring. A sanctions issue may require separate action under Australian sanctions law.

Records should connect the product classification, customer identity, beneficial owners, risk rating, payment, delivery, monitoring review, enhanced measures and reporting decision. Applicable customer, transaction and program records commonly require retention for seven years, although the dealer should use a schedule tied to each statutory record type.

Practical controls for a bullion business

1. Maintain a product register that distinguishes bullion from other precious metals, stones and products.
2. Configure point-of-sale and purchasing systems for the A$5,000 bullion CDD point and the separate A$10,000 tests.
3. Link customers and transactions across branches, online channels, invoices, instalments, payers and collectors.
4. Prevent completion where required CDD is outstanding, and give staff a documented escalation path for unusual conduct.
5. Reconcile physical-currency transfers to TTR decisions and review possible structuring for an SMR decision.
6. Test a sample of customer files and reports, correct gaps and update the risk assessment when products or payment methods change.