For precious metals dealers
Linked transactions for Australian precious-items dealers
For dealers in precious metals, stones and products, linked transactions perform a specific legal job. Physical-currency and virtual-asset payments that are connected can be added together to decide whether a purchase or sale reaches the A$10,000 threshold for the precious-items designated service. That aggregation rule is not the same as threshold transaction reporting: AUSTRAC says each individual physical-currency transaction is assessed separately for a TTR. A series of A$2,000 cash instalments may therefore make the jewellery service regulated when the linked total reaches A$10,000, while no individual instalment produces a TTR. The pattern may still raise a structuring suspicion and require an SMR. This guide explains how to identify connections, capture data across channels, respond at the threshold and avoid merging the service-scope, TTR and SMR decisions.
See the precious-items dealers AML/CTF workspaceStep-by-step process
Record the qualifying item and payment
Capture the precious item, invoice, customer, payment method and regulated payment amount for each transaction.
Search for connections
Check prior deposits, instalments, invoices, items, exchanges, refunds, stores, channels and related payers for a common sale or purpose.
Calculate the service threshold
Add linked physical-currency and virtual-asset components for qualifying items and pause the service before the A$10,000 threshold is reached where CDD is incomplete.
Assess each cash transfer for a TTR
Separately identify any individual physical-currency transaction of A$10,000 or more; do not aggregate separate payments solely to create a TTR.
Review suspicious patterns
Investigate deliberate splitting, threshold questions, third-party payers and inconsistent explanations, then escalate an SMR where reasonable grounds arise.
Retain both decisions
Keep the connection analysis, service-scope result, CDD evidence and separate TTR and SMR decisions with the transaction record.
Understand what makes transactions linked
Transactions may be linked or appear linked when they concern the same item, underlying sale, invoice, arrangement, purpose or outstanding balance. Instalments under a lay-by, deposits and final payments, multiple payments for one invoice, one payment covering several connected invoices, or a return and cash top-up for a related replacement can all require consideration together. Connections may also appear through the same customer, similar items, a short period or a deliberate split.
There is no universal time period after which connected payments automatically reset. AUSTRAC's examples include an exchange and top-up months after an original purchase. Use the commercial substance and what the business knows about the customer and transaction history rather than an arbitrary daily or monthly cut-off.
Capture enough data below the threshold
A dealer that accepts sub-threshold physical currency or virtual assets needs a way to recognise later connections. Capture a transaction identifier, customer or purchaser information appropriate to the process, qualifying item type and value, invoice, payment method and amount, store or channel, date, staff member, refund or exchange link and any third-party payer. The design should be proportionate and consistent with privacy obligations, but it cannot leave every cash sale invisible until after the threshold has been crossed.
Link data across stores, tills, ecommerce, repairs, buy-back desks and virtual-asset channels. A customer can make payments through different employees or related people. Train staff to search and escalate rather than creating a fresh anonymous record whenever a person changes store or payment method.
Recognise when the designated service threshold is reached
Add the physical-currency and virtual-asset components of linked transactions for qualifying precious items. The service threshold can be reached by cash, virtual assets or a combination. Payment only by bank transfer or debit or credit card does not create this particular designated service. For a mixed basket, count the qualifying precious items and regulated payment components correctly rather than using the gross receipt without analysis.
The business must be ready to discharge the relevant AML/CTF obligations before providing the designated service. A process that discovers the connection only after completing the sale is too late. Configure alerts below the threshold and pause completion where required so CDD, risk and approval steps can occur at the right time.
Keep the TTR calculation separate
A TTR concerns an individual transfer of A$10,000 or more in physical currency. AUSTRAC treats multiple physical-currency transactions as separate transactions for TTR purposes, even when close together. Do not combine separate A$2,000 cash instalments and submit a TTR merely because the linked precious-item service total exceeds A$10,000. Submit a TTR for each individual physical-currency transaction that itself reaches the threshold, generally within ten business days.
Virtual assets are part of the precious-items service threshold but are not physical currency and do not themselves trigger a TTR. A mixed payment can therefore create a regulated precious-items service without a TTR, or create both the regulated service and a TTR when one physical-currency transfer is A$10,000 or more. Record both decisions separately.
Escalate possible structuring and other suspicious patterns
Splitting can be legitimate, so linked transactions are not automatically suspicious. Escalate when the customer asks to keep each payment under a threshold, changes staff or locations, recruits third-party payers, resists identification, gives inconsistent explanations or shows unusual knowledge of reporting boundaries. Consider the whole pattern. Apply enhanced CDD only when a current trigger is met, such as a high customer risk rating or an unusually complex transaction, rather than treating the linked-transaction rule itself as an automatic trigger.
Red flags and the A$10,000 service threshold are not the SMR test. If the facts create reasonable grounds for a relevant section 41 suspicion, lodge an SMR within the statutory deadline even if the transaction is declined. An SMR and a TTR can both be required for the same activity, but one does not replace the other. Restrict specified SMR-related information and do not disclose it where that would or could reasonably be expected to prejudice an investigation. Retain the connection evidence, analysis and each decision.
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
- AUSTRAC — Precious metals, stones and products designated services
- AUSTRAC — Examples of linked transactions in practice
- AUSTRAC — Threshold transaction reports
- AUSTRAC — Enhanced customer due diligence
- AUSTRAC — Suspicious matter reports
- AUSTRAC — Tipping off
- Federal Register of Legislation — AML/CTF Act 2006
Frequently asked questions
Is there a fixed time limit for deciding whether precious-item payments are linked?
No fixed reset applies simply because time passes. Consider the same items, invoice, arrangement, purpose, balance, customer and transaction history. AUSTRAC gives an example where a later exchange and cash top-up remains linked to the original sale. Your policy should focus on connection, not an arbitrary calendar cut-off.
Do separate cash instalments create a TTR when their total reaches A$10,000?
Not merely because their total reaches A$10,000. AUSTRAC says each physical-currency transaction is separate for TTR purposes. A TTR is required for each individual physical-currency transaction of A$10,000 or more. The instalments may still aggregate for precious-items service scope and may indicate structuring that requires SMR consideration.
Can payments made by different people be linked?
Potentially. Examine whether the payers are acting for the same customer, paying the same invoice or balance, buying connected items or sharing a common purpose. Third-party involvement is a relevant fact, not automatic proof of wrongdoing. Record the relationship and assess it with the wider pattern.
Does a virtual-asset instalment count toward the precious-items threshold?
Yes, where it is part of a qualifying purchase or sale. Physical currency and virtual assets can be combined across linked transactions to reach the A$10,000 designated-service threshold. Virtual assets are not physical currency, so the virtual-asset component does not itself trigger a TTR.
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.