Tranche 2
AML/CTF for dealers in precious metals and stones: cash thresholds, CDD and TTRs
Gold, silver, platinum and gemstones convert cash into portable, hard-to-trace value — which is why dealers in precious metals and stones join the AML/CTF regime under Tranche 2. For jewellers and bullion dealers, the obligations centre on one number: A$10,000 in physical cash.
When a sale becomes a designated service
For dealers, the designated service is selling or purchasing precious metals or stones where the transaction involves physical currency of A$10,000 or more (or the equivalent in foreign currency). Below the cash threshold, routine retail sales are not captured. Once a single transaction crosses it — including split payments that together reach A$10,000 in cash — the obligation attaches.
What you must do for a captured transaction
- Verify the customer's identity before completing the transaction — government photo ID, checked and recorded
- For a company or trust buyer, identify the entity and the individuals behind it
- Screen the customer against the DFAT sanctions list and consider PEP status
- Record the transaction details: items, value, payment method and date
- Lodge a threshold transaction report (TTR) with AUSTRAC within 10 business days
- Keep every record for seven years
Threshold transaction reports: the discipline dealers need
TTRs are routine, not accusations — they report the fact of a large cash transaction. The risk is missing them: a ten-business-day clock, cash totals spread across a layby or multiple visits, and staff who do not realise separate payments aggregate. Build a simple counter rule: any customer whose cash payments toward a purchase reach A$10,000 triggers verification and a TTR, full stop.
Red flags AUSTRAC expects dealers to notice
A structured refusal is itself suspicious. Where you suspect a transaction is linked to crime, lodge a suspicious matter report — generally within three business days — and say nothing to the customer: tipping off is a criminal offence.
- A customer who buys high-value items with cash and shows no interest in price, design or quality
- Requests to split a sale into sub-threshold amounts or across multiple days ('structuring' — itself a red flag to report)
- Third parties paying, collecting or taking delivery for someone who stays off the paperwork
- Rapid buy-back requests, or bullion bought with cash and quickly resold
- Reluctance to provide identification for a cash transaction at the threshold
Setting the business up
- Enrol with AUSTRAC if any of your transactions involve A$10,000 or more in cash
- Appoint your AML/CTF compliance officer and write a proportionate program — for most dealers, a short document focused on the cash threshold
- Train counter staff on the verification step, aggregation and escalation — they are the control
- Keep verification and TTR evidence retrievable for seven years
Frequently asked questions
Does Tranche 2 apply to every jewellery sale?
No. The designated service attaches to transactions involving physical currency of A$10,000 or more (including aggregated cash payments toward one purchase). Ordinary card-based retail sales are not captured — though your program should still define how staff treat unusual cash behaviour below the threshold.
What if a customer pays A$6,000 cash and A$6,000 by card?
Only the physical currency component counts toward the threshold: A$6,000 in cash does not trigger a threshold transaction report. But deliberate splitting to stay under the threshold is structuring — a red flag that may itself warrant a suspicious matter report.
We buy second-hand gold as well as sell. Are purchases captured?
Buying precious metals from a customer can also be a designated service where cash of A$10,000 or more is paid to the customer. Verify the seller, record the transaction and lodge the report within 10 business days.
How long do we keep the records?
Seven years — identity verification evidence, transaction details and copies of any reports lodged with AUSTRAC.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser.