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Guide · general information, not legal advice

AML/CTF for dealers in precious metals, stones and jewellery

Last checked 25 September 2026 against the AML/CTF Act compilation C2026C00274, the AML/CTF Rules 2025 (F2025L01026) and the Transitional Rules 2026 (F2026L00393)

For jewellers and dealers. From 1 July 2026, buying or selling precious metals, stones or jewellery became a regulated service when the purchase involves A$10,000 or more in cash or virtual assets. This page sets out what is caught, what follows, and where to find AUSTRAC's free jeweller kit. Our kit does not cover dealers, and this page says why.

The short version

Buying or selling precious metals, precious stones or jewellery in the course of a business became a designated service on 1 July 2026, when the purchase involves A$10,000 or more in physical currency or virtual assets, in one transaction or in several that are, or appear to be, linked.1 A business that provides that service is a reporting entity, with enrolment, program, customer checking, reporting and record-keeping obligations.2

Our kit does not cover dealers

We do not sell a dealers edition, and our set-up service does not take dealers. Start with AUSTRAC's free jeweller program starter kit (opens in a new window). The reasons are below.

What is caught

Table 2 item 2 of section 6 covers "buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000". The items are precious metal, precious stones, precious products, or any combination of them. The customer is the buyer or the seller, as the case may be. s 6

What the Act counts as precious
Term What it covers Law
Precious metal Gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium, any substance the Rules prescribe, and an alloy with at least 2% by weight of any of them, manufactured or not s 5A
Precious stone A substance of gem quality with market-recognised beauty, rarity and value, whether natural, synthetic or reconstructed. The Act names beryl, corundum, diamond, garnet, jadeite jade, opal, pearl and topaz, and any substance the Rules prescribe, as kinds of precious stone. s 5A
Precious product Jewellery, a watch, another object of personal adornment, or goldsmiths' or silversmiths' wares, made of, containing or having attached any precious metal or stone s 5A

On the words of item 2, the test is how the purchase is paid, not what the business calls itself. AUSTRAC gives the example of a retail store that sells gold jewellery, which it says should select dealers in precious metals, stones and products in its regulation check.3 Before deciding, use AUSTRAC's Check if you may be regulated tool, and read its examples of linked transactions for dealers and its page on regulation options for dealers (each opens in a new window).

Bullion is a separate item. Buying or selling bullion in a bullion-dealing business is Table 2 item 1, a designated service since the Act was made in 2006. It is not one of the services added on 1 July 2026. s 6

What follows if you provide the service

Main obligations for a dealer that provides a Table 2 item 2 service
Obligation In short Law
Enrolment Enrol directly with AUSTRAC. The date was 29 July 2026 if you were already providing the service before 1 July 2026 and no other designated service; otherwise within 28 days of your first designated service s 51B
AML/CTF program Your ML/TF risk assessment plus your AML/CTF policies, documented before the first service s 26B s 26C s 26N
Compliance officer Designate one at management level, resident in Australia and fit and proper, within 28 days of your first designated service; notify AUSTRAC within 14 days s 26J s 26K s 26M
Customer checks Identify and verify the customer before providing the service; customers you already had at 1 July 2026 are pre-commencement customers s 28 s 36
Suspicious matters Report within 3 business days of forming the suspicion, or 24 hours for terrorism financing. Do not tip off the customer s 41 s 123
Threshold transactions Report a transfer of A$10,000 or more in physical currency within 10 business days s 43 s 5
Annual compliance report First period 1 July 2026 to 30 June 2027; lodge between 1 July 2027 and 30 September 2027 s 47 Rules 9-9
Records Transaction records for 7 years from when they are made; customer-check records for 7 years after the relationship or one-off transaction ends s 107 s 111

The definition of a threshold transaction also lets regulations add other kinds of transaction, including ones involving virtual assets. We have not checked those regulations, so ask AUSTRAC if you take virtual assets.4

The maximum civil penalty a court can order is 100,000 penalty units (A$36.4 million) for a body corporate and 20,000 penalty units (A$7.28 million) for anyone else, at the A$364 penalty unit that has applied since 1 July 2026.5

Key dates

  1. 1 July 2026

    Program, customer checking, reporting and record-keeping obligations began for Table 2 item 2 dealers.

    Sch 3 item 11
  2. 29 July 2026

    Enrolment was due for dealers already providing the service before 1 July 2026, and no other designated service. A dealer that starts later has 28 days from its first designated service. The obligation continues until you enrol.

    Not enrolled yet? You enrol directly with AUSTRAC. Enrol with AUSTRAC (opens in a new window)

    Sch 3 item 12 s 51B
  3. 28 August 2026

    AUSTRAC said it had begun issuing section 167 notices to businesses that appear to be providing designated services but have not enrolled. It named jewellers among the businesses the notices go to.

    s 167 AUSTRAC news article

As at 17 September 2026, AUSTRAC's enrolment table listed 320 enrolments for jewellers and dealers in precious metals and goods. AUSTRAC Enrol with us overview

AUSTRAC's free jeweller kit

AUSTRAC publishes five free program starter kits, one of them for jewellers. It describes the jeweller kit as helping "create an AML/CTF program for your small jewellery business".6 Each kit is built for businesses that meet AUSTRAC's suitability criteria, and AUSTRAC says the kits are not a substitute for legal advice. We have not reviewed the jeweller kit's criteria or documents, so read its getting-started page before relying on it. If your business falls outside its profile, take advice from a lawyer or AML/CTF adviser who works with dealers.

AUSTRAC's jeweller program starter kit (opens in a new window)

Why our kit does not cover dealers

Our kit is not for dealers, and we will not sell it to you for a dealing business. There are three reasons.

  1. It is built for other services. Each of our four editions is built on one of AUSTRAC's accountant, real estate, conveyancer and legal profession kits, and checked against the provisions for those sectors: Tables 5 and 6 of section 6. A dealer provides a Table 2 item 2 service, which none of our editions deals with.
  2. Your program has to fit your own risks. Your risk assessment must deal with your own services, customers, delivery channels and countries. s 26C A dealer's risks come from counter sales, cash and virtual-asset payments, linked purchases and threshold reporting. Documents written for an accounting practice or a real estate agency would leave those gaps open.
  3. We have not built or checked dealer documents. We only sell what we have checked against the law for that sector, and we have not done that for dealers. Our set-up service does not take dealers for the same reason.

If your business also provides a real estate or professional service, the am I regulated? questions cover those.

Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.

Sources

Law is quoted from the authorised text on the Federal Register of Legislation, opened 25 September 2026. AUSTRAC pages are guidance, not law. AUSTRAC links open in a new window; AUSTRAC has not reviewed or endorsed this guide.

  1. AML/CTF Act s 6(3), Table 2, item 2; s 5A. legislation.gov.au/C2006A00169/latest/text

  2. AML/CTF Amendment Act 2024 (C2024A00110), Schedule 3 items 11 and 12. legislation.gov.au/C2024A00110/latest/text

  3. AUSTRAC, "Check if you may be regulated", read 25 September 2026. Guidance, not law.

  4. AML/CTF Act s 5, definition of "threshold transaction", paragraphs (a) and (ca).

  5. AML/CTF Act s 175(4)–(5); Crimes (Amount of a Penalty Unit) Instrument 2026 (F2026N00424), s 5. legislation.gov.au/F2026N00424/latest/text

  6. AUSTRAC, "Program starter kits", read 25 September 2026. Guidance, not law.

Questions

Do you sell a dealers edition?

No. Our kit and our set-up service cover accounting practices, real estate agencies, conveyancers and legal practices only. Please do not buy our kit for a dealing business. AUSTRAC publishes a free jeweller program starter kit; start there.

Is bullion dealing newly regulated?

No. Buying or selling bullion in the course of a bullion-dealing business is Table 2 item 1 of the Act, and has been a designated service since the Act was made in 2006. The service added from 1 July 2026 is Table 2 item 2: buying or selling precious metals, precious stones or precious products where the purchase involves A$10,000 or more in physical currency or virtual assets.

What is the cash threshold?

Two different rules use A$10,000. Table 2 item 2 turns on a purchase involving physical currency or virtual assets totalling A$10,000 or more, in one transaction or in several that are, or appear to be, linked. Separately, a transfer of A$10,000 or more in physical currency is a threshold transaction, which you report to AUSTRAC within 10 business days (s 5; s 43). AUSTRAC publishes examples of linked transactions for dealers.