If you’re selling gold, silver, gemstones, or jewellery in Australia, you’re classified as a reporting entity under AUSTRAC’s AML/CTF framework, and that comes with real obligations. AUSTRAC compliance for jewellers and bullion dealers isn’t optional, and getting it wrong can mean significant penalties, or worse, criminal prosecution.
The rules cover everything from customer identification and verification (KYC) to suspicious matter reports, threshold transaction reports, and ongoing compliance programs. Whether you’re a sole trader crafting bespoke pieces or a bullion dealer processing high-value transactions, AUSTRAC expects the same standard of compliance.
This guide breaks down exactly what you need to do, registration, reporting thresholds, record-keeping, and how to build a compliant AML/CTF program that actually works for your business. We’ll also cover how tools like StackGo’s IdentityCheck can simplify your KYC obligations by running identity verification directly inside your existing software, so you’re not juggling yet another platform just to meet your regulatory requirements.
Understand when AUSTRAC rules apply in 2026
Not every transaction you process triggers a reporting obligation, but AUSTRAC classifies dealers in precious metals and precious stones as reporting entities under the AML/CTF Act. That means the framework applies to your business from the moment you provide a designated service, regardless of whether you’re a sole trader or a large wholesale bullion operation.
Who qualifies as a reporting entity
Dealers in precious metals (gold, silver, platinum) and precious stones (diamonds, rubies, sapphires, and similar) are designated service providers under the AML/CTF Act 2006. The rules apply when you buy, sell, or exchange these items in a business context. If you run a jewellery retail shop, operate a bullion trading desk, or process scrap gold purchases, you fall within scope.
The 2024 AML/CTF reforms, which took effect in stages through 2026, expanded obligations across professional services sectors. For jewellers and bullion dealers, the core obligations remain consistent, but your compliance program must reflect the updated rules, including revised customer due diligence (CDD) standards and updated risk assessment requirements.
Key thresholds that trigger your obligations
Your most important benchmark is the $10,000 cash threshold. Under the AML/CTF Act, any physical currency transaction of $10,000 or more (or the foreign equivalent) requires you to submit a Threshold Transaction Report (TTR) to AUSTRAC within 10 business days. This applies whether the customer pays in one transaction or you have reasonable grounds to suspect multiple transactions are structured to avoid the threshold.
If a customer pays $9,500 in cash across two visits in the same day for a single purchase, that is structuring, and it still triggers your reporting obligations.
Cryptocurrency payments also fall under AUSTRAC’s oversight. If you accept digital currency in exchange for precious metals or stones, you must apply the same due diligence and reporting standards as you would for cash. AUSTRAC compliance for jewellers and bullion dealers covers both payment types equally.
Step 1. Set your cash and crypto payment policy
Before you touch enrolment or build a compliance program, you need a written payment policy that sets the rules for how your business handles cash and digital currency. This policy forms the foundation of your AML/CTF obligations and tells staff exactly what to do before a transaction is processed.
Define your cash acceptance limits
Your policy must state clearly that any single cash transaction of $10,000 or more triggers an automatic Threshold Transaction Report. Set an internal alert threshold below that, around $8,000, so your team flags high-value cash sales before they reach the legal reporting line. Document who is responsible for submitting the TTR and within what timeframe.
Never accept a split cash payment for a single item if the total value hits $10,000 or more – splitting the payment does not remove your reporting obligation.
Cover cryptocurrency payments
Crypto payments carry the same obligations as cash under Australian AML/CTF law. Your policy should name which digital currencies you accept, if any, and confirm that customer due diligence runs before settlement, not after. AUSTRAC compliance for jewellers and bullion dealers requires you to treat a Bitcoin payment for a $15,000 gold bar exactly the same as banknotes – verify the customer’s identity, document the transaction, and report if the threshold applies.
Step 2. Enrol with AUSTRAC and assign ownership
Before you can submit any reports or legally operate as a reporting entity, you must enrol your business with AUSTRAC. Enrolment is mandatory and must happen before you provide any designated service. If your business is already trading, enrol immediately.
How to enrol through AUSTRAC Connect
AUSTRAC uses its online portal, AUSTRAC Connect, to manage enrolments and reporting. Navigate to the AUSTRAC Connect portal at austrac.gov.au and create a business account. You’ll need your ABN, business structure details, and a description of the designated services your business provides, specifically dealing in precious metals or precious stones.
Complete your enrolment before your first high-value transaction, not after – AUSTRAC treats late enrolment as a breach in its own right.
Work through the portal fields accurately. AUSTRAC will ask you to confirm which AML/CTF designated services apply to your operation.
Assign a compliance officer
Every reporting entity needs a nominated officer responsible for your AML/CTF program. This person manages your compliance obligations, submits reports, and keeps your program current. For small businesses, the owner often takes this role. For larger operations, assign a senior staff member with direct access to transaction records and customer files. Document this appointment formally in writing and keep that record on file.
Step 3. Build your AML/CTF program and run CDD
Your AML/CTF program is the written document that governs how your business identifies, manages, and reports money laundering and terrorism financing risks. AUSTRAC compliance for jewellers and bullion dealers requires you to maintain this program in writing, keep it current, and make it available to AUSTRAC on request.
What your AML/CTF program must include
Your program must cover these core elements:
- Risk assessment: Identify the specific risks your business faces, such as high-cash transactions or anonymous buyers
- Customer due diligence procedures: Document exactly how and when you verify customer identities
- Reporting procedures: Define who submits TTRs and Suspicious Matter Reports (SMRs) and by what deadline
- Staff training plan: Outline how often training occurs and what it covers
- Record-keeping policy: State where records are stored and for how long (minimum seven years)
Review and update your AML/CTF program at least annually, or whenever your business model or risk profile changes.
How to run customer due diligence
CDD requires you to verify a customer’s identity before processing any high-value transaction. For individuals, collect full name, date of birth, and a government-issued photo ID such as a passport or driver’s licence. For businesses, obtain the entity name, ABN, and details of the beneficial owners. Tools like StackGo’s IdentityCheck let you run this verification directly inside your existing CRM, removing the need for manual data entry or separate platforms.
Step 4. Report, record, train, and monitor
Once your program is live, your ongoing obligations under AUSTRAC compliance for jewellers and bullion dealers require you to report transactions, maintain records, train staff, and monitor your controls regularly. This is not a one-time setup. AUSTRAC expects active, continuous compliance from every reporting entity.
Submit your reports on time
You have two core reporting obligations. First, submit a Threshold Transaction Report (TTR) within 10 business days of any cash or crypto transaction at or above $10,000. Second, submit a Suspicious Matter Report (SMR) within 24 hours if you suspect a transaction involves proceeds of crime, and within 3 business days for other suspicious indicators. Use AUSTRAC Connect to lodge both report types.
Missing an SMR deadline is treated as a serious compliance failure, even if you report the matter late.
Keep records and train your staff
Retain all transaction records, customer identification documents, and AML/CTF program versions for a minimum of seven years. Store them securely, with access limited to authorised personnel only.
Run staff training at least once per year and document every session, including dates, attendees, and content covered. Use a simple training log like the one below:
| Date | Staff member | Topic covered | Trainer |
|---|---|---|---|
| 01/02/2026 | Jane Smith | TTR obligations | Compliance officer |
| 01/02/2026 | Tom Reeves | CDD procedures | Compliance officer |
Keep your business ready for AUSTRAC
AUSTRAC compliance for jewellers and bullion dealers is an ongoing commitment, not a one-time setup. Your obligations require you to stay current with regulatory updates, keep your AML/CTF program aligned with your actual business practices, and act quickly when your risk profile changes. Treat your compliance program as a living document that you review at least once a year and update whenever you change how you accept payments, take on new customer types, or expand into new product lines.
Running identity verification manually slows you down and increases the chance of human error. Integrating KYC directly into the software you already use removes that friction and keeps your records clean. If you want to see how that works in practice, explore how IdentityCheck handles AUSTRAC AML/CTF compliance inside your existing software and decide whether it fits your operation before your next high-value transaction lands on your counter.
