AML/CTF for Dealers in Precious Metals and Stones: Tranche 2 Obligations

9 min read · General information, not legal advice · Updated 2026-06-12

If you buy or sell bullion, set diamonds, deal in coloured gemstones, or take cash across the counter for high-value jewellery, a decision is coming that you cannot leave to your accountant at year-end: do you build an AML/CTF capability now, or wait and risk scrambling? The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (“Tranche 2”) brings dealers in precious metals and precious stones into Australia's AML/CTF regime, with new obligations due to commence on 1 July 2026.

This article is for the owner or manager of a bullion business, jeweller or gemstone trader who needs a straight answer to one question: what does my business actually have to do? We will cover the cash thresholds that matter day to day, which of your activities count as “designated services”, and a practical checklist to get ready. This is general information, not legal advice — your specific obligations depend on the designated services you provide, so confirm the detail with AUSTRAC or a qualified adviser.

What Tranche 2 means for the precious-metals trade

Australia has run an AML/CTF regime for years, but it has mostly applied to banks, casinos and financial-service businesses. “Tranche 2” is the long-discussed expansion of that regime to additional sectors — made law through the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024.

The regulator is AUSTRAC (the Australian Transaction Reports and Analysis Centre). AUSTRAC oversees the regime, and the things you will eventually need to do — enrol, and lodge reports — happen through AUSTRAC Online. The date to anchor your planning around is that new obligations for Tranche 2 entities are due to commence on 1 July 2026. High-value, portable goods that hold their value — gold bars, coins, loose diamonds, finished jewellery — are exactly the kind of assets the regime is concerned about, which is why the precious-metals and precious-stones trade is in scope.

Who and what it applies to: designated services

A common misconception is that Tranche 2 captures “jewellers” or “bullion dealers” as a job title. It does not work like that. The regime applies to businesses that provide one or more designated services. You become a reporting entity because of what you do, not the sign above your shop.

The Tranche 2 sectors are:

• Dealers in precious metals and precious stones — the focus of this article.
• Real estate professionals.
• Certain professional service providers — lawyers, conveyancers, accountants, and trust & company service providers — when they provide specified designated services.

For a dealer, the activities that bring you into scope centre on buying and selling precious metals (such as gold, silver and platinum bullion) and precious stones (such as diamonds and coloured gemstones), and dealing in goods made from them. The precise list of captured services — and the cash level at which a transaction triggers obligations — is being set out as the AUSTRAC rules are finalised. The safe approach is to map each of your activities (over-the-counter retail, scrap-gold buying, investment bullion, trade-ins, online sales) against the final rules rather than assume one line of business is in or out. If you provide a designated service, the obligations below apply.

The cash thresholds that matter day to day

Cash is where this regime touches the counter most directly. Two numbers deserve a permanent place in your head and in your point-of-sale process:

• AUD 10,000 in physical currency. When you receive physical currency of AUD 10,000 or more in a transaction, that is a threshold transaction and must be reported to AUSTRAC as a threshold transaction report (TTR). This applies whether it is one $10,000 sale of a gold bar or a single cash payment that crosses the line.
• Watch for structuring. Be alert to a customer deliberately splitting a purchase into several smaller cash amounts to stay under the threshold — for example, paying $9,500 today and returning tomorrow. Structuring to avoid a report is itself a red flag and may warrant a suspicious matter report.

The exact thresholds and triggers for designated services are being confirmed as the AUSTRAC rules are finalised, so treat the AUD 10,000 physical-currency figure as the firm anchor and check the rule detail for your specific services. The practical point: your till and your staff need a reliable way to recognise when a cash amount is approaching or crossing the line, before the goods leave the shop.

The core obligations you will carry

Once your business provides a designated service, you take on the standard obligations that every reporting entity carries. They are not exotic, but they are non-negotiable:

• Enrol with AUSTRAC via AUSTRAC Online, so the regulator knows you are a reporting entity.
• Develop and maintain an AML/CTF program — this is the backbone. It covers your governance arrangements, a documented ML/TF risk assessment (money laundering and terrorism financing risk), and the policies, procedures, systems and controls that flow from that risk picture.
• Conduct customer due diligence (CDD/KYC) — verify who your customer is, including ongoing CDD and transaction monitoring rather than a one-off check at the start.
• Report to AUSTRAC — lodge suspicious matter reports (SMRs) when something doesn't add up, and threshold transaction reports (TTRs) for physical currency of AUD 10,000 or more.
• Keep records — generally for 7 years.
• Appoint an AML/CTF compliance officer (AMLCO) — a named person accountable for the program.

Failure to meet these obligations can attract significant civil and criminal penalties, so they deserve owner- or director-level attention rather than being parked with one busy staff member at the bench.

A dealer readiness checklist

You don't have to do everything at once, but you do need to do things in a sensible order. Here is a checklist an owner can work through:

• Confirm your status. Map your activities — bullion sales, scrap-gold buying, gemstone trading, jewellery retail, trade-ins, online orders — against the designated services to decide whether, and where, you are captured.
• Nominate your AMLCO. Pick the person who will own this. They need standing in the business and the time to do the work.
• Run an ML/TF risk assessment. Document your risks across customers (walk-ins, investors, trade), products (bullion versus retail jewellery), delivery channels (in-store versus online) and geography. Everything else hangs off this.
• Write the AML/CTF program. Turn the risk assessment into governance, policies, procedures and controls that your counter staff can actually follow.
• Set up your CDD process. Decide how you verify identity, when you re-check (ongoing CDD), and how you monitor transactions — including a clear cash-handling rule for amounts at or near AUD 10,000.
• Build reporting muscle memory. Make sure staff know what an SMR and a TTR are, how to spot structuring, and how to escalate. Plan to enrol with AUSTRAC and lodge through AUSTRAC Online.
• Train your team and keep records. Document training, identity verifications and decisions, and store them for the retention period.
• Schedule a review. Treat the program as living — update it as your stock mix, your customers and the AUSTRAC rules change.

Common mistakes to avoid

The dealers who struggle tend to make the same handful of errors. Recognising them early saves a lot of rework:

• Treating it as a back-office afterthought. AML/CTF lives at the counter, where cash and high-value goods change hands. The risk assessment and program must exist before you rely on them.
• Watching only the $10,000 cash line and missing the patterns. A series of just-under-threshold cash purchases, or a customer with no interest in the product who only wants to move cash, can matter as much as a single large transaction.
• Buying a generic template and stopping there. A program that hasn't been tailored to your actual risks and product lines is a document, not a defence. The risk assessment is what makes it yours.
• Confusing one-off ID checks with ongoing CDD. Verifying a buyer once is not the same as monitoring a repeat investor relationship over time.
• Leaving the AMLCO under-resourced. Naming someone is easy; giving them authority, training and time is what makes the role work.
• Poor record-keeping. If you can't show what you did and why, you can't demonstrate compliance. Keep records for the full retention period.
• Waiting for perfect certainty. Some detail will keep firming up as the AUSTRAC rules are finalised, but the foundational steps — status, AMLCO, risk assessment — can and should start now.

Where a template kit can save you time

You do not have to build every document from a blank page. A well-structured, audit-ready template kit — covering the AML/CTF program, a risk-assessment framework, CDD procedures, and reporting and record-keeping templates — gives you a credible starting point that you then tailor to your business's risks. The value is in the time saved on structure and wording, not in pretending compliance is a copy-and-paste exercise. Whatever you start from, the program still has to reflect your real trade — the cash you handle, the products you sell, the customers you serve — and the risk assessment still has to be yours. Used that way, a kit shortens the path; it does not replace the thinking.

The bottom line for dealers

Tranche 2 is not a maybe. With obligations due to commence on 1 July 2026, the dealers who come out of this calmly are the ones who start the groundwork in the months beforehand: confirm whether their services are captured, appoint an AMLCO, complete a risk assessment, and build a program around it. The day-to-day obligations — CDD, watching the AUD 10,000 cash threshold, reporting SMRs and TTRs, and record-keeping — become routine once that foundation is in place.

Again, this is general information rather than legal advice, and your exact obligations depend on the designated services your business provides. Confirm the specifics with AUSTRAC at austrac.gov.au or a qualified adviser before you finalise your approach.