For precious metals dealers
Bullion dealer AML/CTF operations guide for Australia
Bullion is not regulated under the new A$10,000 precious-items payment test. Buying and selling bullion while carrying on a bullion-dealing business is a separate designated service, as is buying bullion from a non-retail customer in the circumstances described by AUSTRAC. The customer does not need to take physical possession: storage holdings and pooled products can still be relevant. Bullion dealers also have a targeted initial-CDD exemption where the retail value is less than A$5,000 and enhanced CDD is not required. That exemption is not permission to ignore suspicious activity, monitoring, reporting or the rest of the AML/CTF program. This guide turns those distinctions into an operating model for customer intake, product classification, transaction processing, reporting and review.
See the precious-items dealers AML/CTF workspaceStep-by-step process
Classify the bullion service
Confirm the product is bullion, identify the business activity and keep collector items and precious products in the correct compliance pathway.
Test the initial-CDD exemption
Record retail value and determine whether enhanced CDD is required; use the exemption only when both statutory conditions are met.
Complete risk-based customer checks
Where CDD is required, establish identity, ownership, purpose, risk, screening and any source information before service delivery.
Capture the bullion transaction
Record product, value, direction, payment, delivery or storage, customer and staff information in a reviewable transaction record.
Monitor and report
Assess unusual patterns, submit each required TTR and SMR separately, and apply enhanced CDD where an SMR is required for a customer whose services will continue.
Test and improve controls
Sample exemptions, CDD, alerts and reports, reconcile stock and customer activity, and update the program when the business changes.
Keep bullion scope separate from precious items
Classify whether a product is bullion based on the statutory and AUSTRAC description: authenticated gold, silver, platinum or palladium of specified quality and fineness, valued by the market price of the contained metal, including relevant bars, ingots, plates, wafers and coins. A coin traded at bullion value can be bullion; a collector or proof coin valued for other characteristics may instead fall into the precious-metals framework if the legal definition is met.
Document the product basis and whether the activity occurs in a bullion-dealing business. A private disposal is not automatically a designated bullion service. A jeweller, refiner, coin dealer or pawnbroker can nevertheless be a bullion dealer when its business activity meets the test. Maintain separate scope rules for bullion and for precious products so staff do not apply the A$10,000 jewellery threshold to a bullion sale.
Apply the sub-A$5,000 initial-CDD exemption correctly
AUSTRAC states that initial CDD is not required where both the retail value of the bullion being bought or sold is less than A$5,000 and enhanced CDD is not required. Test both conditions. Do not divide a transaction or ignore a relationship. A red flag alone is not automatically an enhanced-CDD trigger, but the exemption is unavailable if the customer is high risk, an SMR is required in relation to the customer and services will continue, or another current enhanced-CDD trigger applies. Record the value, customer context, trigger analysis and exemption basis.
The exemption is limited to initial CDD. The business still needs an AML/CTF program, risk-based controls, monitoring while providing designated services, reporting and records. If enhanced CDD is required, conduct initial CDD regardless of the bullion value. A policy that treats every sub-A$5,000 trade as anonymous and invisible would miss repeated behaviour and possible structuring.
Design customer and transaction controls
For CDD-required customers, establish identity, relevant representatives and beneficial owners, purpose and risk before providing the service, subject to any lawful delayed process. Screen relevant people for PEP and targeted-financial-sanctions matters. Collect and verify source-of-funds or source-of-wealth information where a current PEP or enhanced-CDD rule requires it or where a risk identified under the dealer's policies makes the measure appropriate; it is not automatically required for every bullion trade. Differentiate retail customers, wholesalers, refiners, storage customers and customers using pooled products in the risk model.
Capture product, weight, fineness, serial or identifying information where available, market and transaction value, buy or sell direction, payment method, delivery or storage arrangement, account or wallet details where relevant, location, staff member and linked customer records. Reconcile stock and customer transaction information so unusual buy-back, rapid resale or third-party collection patterns can be investigated.
Monitor and report cash or suspicious activity
Assess each individual physical-currency transfer of A$10,000 or more for a TTR and generally lodge within ten business days. Electronic bank transfers and virtual assets are not physical currency for that report, though they remain relevant to customer risk and other obligations. Do not treat a TTR as a substitute for suspicion analysis.
Monitor for activity inconsistent with the customer's profile, attempts to remain below identification or reporting thresholds, unexplained third-party payments or collections, rapid purchases and sales without commercial rationale, unusual storage instructions, or source explanations inconsistent with the trade. These are review indicators, not automatic SMR findings. If the facts create reasonable grounds for a relevant suspicion, submit an SMR within the applicable deadline. If an SMR is required in relation to the customer and services will continue, enhanced CDD applies. Do not disclose specified SMR-related information where that would or could reasonably be expected to prejudice an investigation.
Govern, test and retain the bullion program
Assign accountable personnel, maintain a bullion-specific risk assessment, document policies and escalation paths, train sales and purchasing staff, and ensure senior management receives meaningful information about risks and control failures. Review the program when product types, storage models, payment methods, customer segments or jurisdictions change.
Test exemption decisions, CDD completion, alert handling, TTR timeliness, restricted SMR access and stock-to-customer reconciliation. Retain records showing the service scope, customer, transaction, exemption or CDD basis, monitoring, reporting and decision history. A reviewer should be able to reconstruct why a trade proceeded and which controls applied at that time.
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
- AUSTRAC — Bullion dealers overview
- AUSTRAC — Overview of customer due diligence
- AUSTRAC — Threshold transaction reports
- AUSTRAC — Enhanced customer due diligence
- AUSTRAC — Source of funds and source of wealth
- AUSTRAC — Suspicious matter reports
- AUSTRAC — Tipping off
- Federal Register of Legislation — AML/CTF Act 2006
Frequently asked questions
Are all bullion transactions below A$5,000 exempt from CDD?
No. The AUSTRAC exemption requires both a retail value below A$5,000 and that enhanced CDD is not required. If an enhanced-CDD trigger applies, initial CDD is required regardless of value. The exemption is limited to initial CDD and does not remove program, monitoring, reporting or record-keeping obligations.
Is a privately sold gold bar a designated bullion service?
A private purchase or sale outside carrying on a bullion-dealing business is not the designated service described by AUSTRAC. The facts matter. A business that regularly buys or sells bullion cannot relabel a trade as private merely to avoid its obligations.
Are collector coins always bullion?
No. Coins traded at their bullion value can be bullion. Collector, proof or other coins valued for rarity or features beyond contained metal may not be bullion, although they may be regulated precious metals or products if they meet the relevant definitions and payment conditions. Record the classification basis.
Does a jeweller that sells bullion need a separate program?
It needs an AML/CTF program that covers every designated service and associated risk. AUSTRAC's small-jeweller starter kit does not by itself cover bullion dealing. The business can maintain one integrated program, but it must add bullion scope, risks, the initial-CDD exemption, transaction controls and reporting procedures.
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. See our editorial and correction standards.