Identify the transaction types
Each transaction type has different exposure. A cash purchase of scrap gold is higher touch than a card sale of a finished piece. The risk assessment should rate the types, not the business as a single block.
- Retail sales of new and second-hand items
- Cash purchases of gold, scrap and stones
- Trade-ins and exchanges
- Custom work and repairs that involve receiving property
- Consignment sales and lay-bys
Assess the risk factors
Precious items are attractive to launderers because they are valuable, portable and hard to trace once melted or resold. The assessment should connect each factor to the controls that respond: verification, transaction limits, linked-transaction monitoring and cash reporting.
- Product value, portability and resaleability
- Cash intensity and threshold proximity
- Customer types, including trade customers and repeat sellers
- Linked purchases across stores and time
- Geography and online sales channels
Build controls that fit a store
The controls must survive a busy Saturday. A one-page transaction checklist and a customer link in the point-of-sale record are more effective than a 40-page program kept in the office.
- A transaction checklist for threshold and CDD decisions
- Customer records that link transactions across visits
- Cash handling procedures and TTR triggers
- Approval authority for large or unusual purchases
- Staff training on splitting and other red flags
Review and keep current
A store's risk changes with its products: adding online sales, gold-buying counters or consignment changes the picture. The assessment should be versioned so the store can show its thinking over time.
- Review the assessment when product lines or channels change
- Test the workflow with a controlled transaction
- Refresh staff training on the current thresholds
- Record the review and the changes
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Does every jewellery store need a full risk assessment?
A reporting entity must assess its ML/TF/PF risk and maintain a written program. The assessment should be proportionate to the store's actual products, customers and channels.
What is the highest risk transaction type for a jeweller?
Cash purchases of gold, scrap and stones are typically the highest touch because they are valuable, portable and can be used to convert cash into an untraceable asset.
How do we detect linked transactions in a store?
Link customer records across visits and transactions, monitor repeat purchases near thresholds and train staff to recognise splitting. The program should define the detection method.
Can a small store use a simplified program?
The program must reflect the business's assessed risk. AUSTRAC's starter kits are an optional starting point for eligible small practices; confirm the suitability criteria and customise.
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.