What counts as bullion under AUSTRAC rules?

Bullion is gold, silver, platinum, or palladium in bar, ingot, or wafer form. It is a separate designated service to jewellery or precious stones, and is regulated at any transaction value through any payment method — there is no $10,000 threshold for bullion.

Is bullion regulated differently to other precious metals under AUSTRAC?

Yes. Bullion dealing is a designated service regulated at any transaction value regardless of payment method. Dealing in other precious metals, precious stones, or precious products (including jewellery) is only in scope once a cash or virtual asset transaction reaches $10,000 or more, subject to the documented no-cash-policy exemption.

What if I only accept card payments — am I still regulated by AUSTRAC?

If you deal in bullion, you are regulated regardless of payment method. If you deal only in other precious metals, stones, or products, and you have a clear, documented business policy never to accept cash or virtual asset payments of $10,000 or more and strictly enforce it, you may not be regulated for those transactions. AUSTRAC recommends documenting this policy explicitly in writing, including staff instructions. This exemption is narrow and subject to strict conditions — do not assume cash transactions are permitted without verifying eligibility. Seek legal advice if unsure.

Do refiners and precious metals wholesalers need to comply with AUSTRAC Tranche 2?

Yes, if refining, wholesaling, or otherwise dealing in bullion or precious metals falls within the designated services under the AML/CTF Act 2006. Bullion dealing is regulated at any value. If your business enrols as a reporting entity, you must implement an AML/CTF Program, conduct customer due diligence, and meet all reporting obligations, which are now in effect since 1 July 2026.

What is a Threshold Transaction Report and when must precious metals dealers submit one?

A Threshold Transaction Report (TTR) must be submitted to AUSTRAC for any cash transaction of $10,000 or more, including physical currency and virtual assets. For dealers in precious metals, stones, or products, this means any single sale or purchase where the customer pays $10,000 or more in cash. The report must be submitted via AUSTRAC Online within 10 business days of the transaction.

What is structuring and why is it a criminal offence for precious metals dealers?

Structuring is when a customer deliberately splits a transaction into amounts below $10,000 to avoid triggering a Threshold Transaction Report. Under the AML/CTF Act 2006, structuring is a criminal offence. Dealers must be alert to customers making multiple smaller purchases within a short period that together would exceed $10,000.

How do I submit a Suspicious Matter Report to AUSTRAC?

Log into AUSTRAC Online at online.austrac.gov.au, select Reporting, then Submit SMR. Complete all mandatory fields including a detailed narrative of the suspicious circumstances. Terrorism financing suspicions must be reported within 24 hours. All other SMRs must be submitted within 3 business days.

What records must precious metals dealers keep and for how long?

Different AML/CTF record categories have different retention rules and statutory triggers. Program records, CDD records, transaction records, reporting records and training or program-compliance records must be retained for their applicable statutory periods. Records must be stored securely and be retrievable for AUSTRAC examination or court proceedings.

Does the $10,000 cash rule apply per item or per transaction?

For non-bullion precious metals, stones, and products, the $10,000 threshold applies per transaction, including linked transactions. A single sale of multiple items totalling $10,000 or more in cash triggers the TTR reporting obligation. AUSTRAC also requires vigilance for linked transactions — multiple purchases structured to stay below the threshold individually may still trigger reporting and SMR obligations. Bullion transactions are reportable at any value.

What if my customer pays partly cash, partly card?

If the total transaction value is $10,000 or more and any portion is paid in cash, a Threshold Transaction Report is required for the cash component. You must report the full cash amount paid, even if only part of the purchase price was settled in physical currency. The card component does not reduce the cash reporting obligation.

Do precious metals dealers need to verify identity for every sale?

Customer due diligence is required before providing a designated service. For bullion dealers, this applies regardless of transaction value. For other precious metals dealers, this means verifying identity for cash transactions of $10,000 or more, and applying enhanced due diligence for high-risk customers or transactions. Your AML/CTF Program must specify your thresholds and procedures.

Can a dealer refuse a sale if a customer won't show ID?

Yes. Under your AML/CTF Program, you must not provide a designated service if you cannot complete the required customer due diligence. If a customer refuses to provide identity documents for a transaction that triggers your CDD obligations, you must decline the transaction and may be required to file a Suspicious Matter Report.

What is a PEP and why does it matter for a precious metals business?

A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public position — such as a government minister, senior official, or their close associate. Transactions with PEPs carry higher money laundering risk and require enhanced CDD under your AML/CTF Program, including verifying the source of funds for high-value bullion or precious metal purchases.

Do I need a separate compliance officer or can it be the owner?

The owner or a senior employee can be designated as the AML/CTF Compliance Officer — there is no requirement for a dedicated full-time role. The Compliance Officer must be clearly named in your AML/CTF Program, responsible for staff training, AUSTRAC reporting, and reviews required under the applicable statutory framework.

What is beneficial ownership and why does it matter for precious metals dealers?

Beneficial ownership refers to the natural person who ultimately owns or controls a company or trust making a purchase. Dealers must identify and verify the beneficial owner of any corporate customer that conducts high-value or suspicious transactions. Obscuring beneficial ownership is a known money laundering technique and a red flag under AUSTRAC guidance.

Do precious metals dealers need to verify the identity of wholesale suppliers?

Your CDD obligations primarily apply to customers — parties to whom you provide a designated service. For wholesale suppliers, you should apply appropriate due diligence proportionate to your risk assessment, particularly if dealing in large volumes of bullion or precious metals. Your AML/CTF Program should specify your supply chain risk procedures.

What happens if my business misses the 29 July 2026 enrolment deadline?

Operating as a reporting entity without enrolling with AUSTRAC is a contravention of the AML/CTF Act 2006 and may attract civil or criminal penalties. AUSTRAC has indicated it will take a risk-based approach to enforcement, but businesses required to enrol must comply with their applicable enrolment timing. Enrolment is available through AUSTRAC Online.

Does Klyvon's output satisfy AUSTRAC's AML/CTF program requirements?

Klyvon generates compliance documents built on AUSTRAC's official guidance and citing the AML/CTF Act 2006 and AML/CTF Rules 2025 throughout. The documents are personalised to your business and structured to meet the risk management framework and CDD procedure requirements under the Act. They are a strong starting point — we recommend review by a qualified AML/CTF adviser before operational reliance.

Does Klyvon include sanctions screening?

Targeted financial sanctions screening is now part of your AML/CTF program obligation under the AML/CTF Rules 2025 — not a separate exercise. Klyvon's generated program includes the required policy controls for targeted financial sanctions. You will still need to screen clients against the DFAT Consolidated List as part of your CDD workflow. Klyvon does not run live screening checks, but your program documents exactly when and how to do it.

How often must precious metals dealers get an independent evaluation of their AML/CTF program?

At least once every 3 years, and more often if appropriate to the size and complexity of your business. The independent evaluation must assess: your ML/TF risk assessment against the Act and Rules, the design of your AML/CTF policies, your actual compliance with those policies, and whether you're appropriately identifying, assessing, and mitigating ML/TF risk. Findings go in a written report to your governing body or a responsible senior manager.

I started providing a designated service after 1 July 2026 — do I still need to enrol by 29 July 2026?

No. The 29 July 2026 date only ever applied to businesses that were already providing a designated service on 1 July 2026, and that date has passed. If you started after 1 July, you have 28 days from the date you started to enrol with AUSTRAC — this rule applies on an ongoing basis, not just around the Tranche 2 rollout. Full explanation and worked examples: https://www.klyvon.com.au/austrac-enrolment-28-day-rule.

Updated August 2026

Field Guide · Bullion & Precious Metals

One metal, two rules. Know which one applies.

Bullion is regulated at any value, no matter how it's paid. Everything else in the sector is scoped by a single number: $10,000. Here's what that split means for your obligations.

Generate my compliance documents →See red flags

Any value
Bullion threshold: $10,000+
Other precious metals: 3 days
SMR lodgement: 29 Jul
Transitional deadline (passed)

⚠ Enrolment opened: 31 March 2026austrac.gov.au ↗

In this guide

Does my business need to comply?Red flags the sector should watch for What Klyvon generates for you What AUSTRAC requires, step by step Frequently asked questions Get compliant with Klyvon

I. Two Rules, One Sector

Does my precious metals or bullion business need to comply with AUSTRAC?

One split decides everything. See it first, then the detail.

Bullion

Any value

Gold, silver, platinum or palladium in bar, ingot or wafer form. Regulated regardless of transaction amount or payment method — no $10,000 threshold applies.

Other precious metals, stones & products

$10,000+

Jewellery, watches, precious stones and other products — reportable when a single transaction or linked transactions reach $10,000 or more in cash or virtual assets.

Rule of thumbBullion by the bar. Everything else by the dollar.

ullion carries no threshold at all. The moment you deal in gold, silver, platinum, or palladium in bar, ingot, or wafer form, you're regulated — the amount and the payment method don't matter. Everything else in the sector runs on a different rule entirely: a single number, $10,000, that decides whether a cash or virtual-asset transaction pulls you into scope.

That split trips people up more than almost anything else in the sector's obligations — a jeweller who also stocks bullion bars can be fully out of scope for their jewellery counter and fully in scope for the safe behind it, at the same time. Businesses with a clear, documented policy prohibiting acceptance of cash or virtual asset payments of $10,000 or more — and that strictly enforce it — may not be regulated for non-bullion transactions. Bullion dealers remain regulated regardless of this policy.

“Bullion dealing is regulated at any transaction value through any payment method — there is no $10,000 threshold for bullion.”
— AML/CTF Act 2006, designated services

II. What AUSTRAC Watches For

Ten patterns published for this sector specifically

None of these alone proves anything — a customer can tick one box for an entirely ordinary reason. What matters is whether, taken together, a reasonable person in your position would start to wonder.

Most-cited indicator

Buying and selling at a loss

Frequent bullion trades at a loss — a named AUSTRAC indicator, since no rational investor repeats this with no offsetting benefit.

Most-cited indicator

Linked transactions under $10,000

Splitting payments across days or branches to stay under the threshold — a structuring pattern AUSTRAC names for this sector specifically.

No explanation of source of funds

Repeated high-value cash purchases with no clear source of funds.

Third-party payment or collection

Someone else paying for or collecting bullion on the customer's behalf, with no disclosed relationship.

Scrap or melted material

Once metal is melted down, the true source becomes very hard to trace — a specific vulnerability AUSTRAC's bullion risk assessment names.

Pooled custodial arrangements

Storage or pooled bullion arrangements add a layer of separation between customer and asset.

FATF grey or black list exposure

Funds from, or customers resident in, high-risk jurisdictions carry elevated ML risk.

Rapid buying and reselling

Quick resale of the same bullion, particularly at a loss, may be placing or layering proceeds.

Virtual asset payments

Cryptocurrency for high-value bullion, especially in volume or from unknown parties.

Wholesale volume anomalies

A small operator suddenly moving industrial quantities of bullion — refining can make identifiable metal untraceable.

III. What You Get

Four documents, built for your specific business

Not a generic template — your name, your compliance officer, your services, generated for review.

AML/CTF Program

Your firm-specific program citing the AML/CTF Act 2006 throughout — the bullion no-threshold rule, the $10,000 cash threshold, TTR obligations, and structuring detection.

Client Due Diligence Forms

CDD procedures for individual and company clients with bullion-specific enhanced CDD triggers and source-of-funds requirements.

Compliance Officer Letter

A record of the business's compliance-officer designation. The business remains responsible for ensuring the designated individual meets the applicable requirements.

SMR Assistant

When suspicion arises, you have 3 business days to file. Klyvon prepares an SMR draft from the information entered for review before submission through AUSTRAC Online.

IV. What AUSTRAC Requires

Eight steps every in-scope dealer must have completed

Klyvon generates the documents this list requires automatically — enrolment and training are the two steps that stay yours to action.

Set up the program

Enrol with AUSTRAC now if not enrolled

Register at online.austrac.gov.au. You'll need your ABN, business details, and the designated services you provide — bullion dealing, wholesaling, refining, or precious stones and products. Enrolment has to be active before you can lodge anything.

Appoint a Compliance Officer in writing

Name an individual — owner or senior employee — responsible for your program, AUSTRAC reporting, and staff training. No dedicated full-time role is required; it just has to be a named person with clear responsibility.

Complete a written ML/TF risk assessment

Assess your exposure across client types, transaction values, payment methods, and geographic risk. If you deal in bullion, refine precious metals, or accept scrap or melt-down material, address provenance documentation and how you verify ownership of anything held in storage or pooled arrangements.

Implement a written AML/CTF Program

Your Program must cover CDD procedures, transaction monitoring, TTR obligations, SMR procedures, and record-keeping policy — built around the two-track threshold rule that defines this sector.

Run it day to day

Train relevant personnel on obligations and red flags

Provide initial and ongoing AML/CTF training for personnel performing relevant functions, appropriate to their functions, relevant ML/TF risks and responsibilities.

Submit Threshold Transaction Reports for $10,000+ cash

10 business days

Any single cash transaction of $10,000 or more must be reported to AUSTRAC via AUSTRAC Online within 10 business days. Bullion dealers apply CDD regardless of transaction value — there's no threshold to wait for.

Submit Suspicious Matter Reports when suspicion arises

3 days / 24 hrs

If you suspect a customer is engaged in money laundering, terrorist financing, or structuring, submit an SMR within 3 business days — or 24 hours for terrorism financing.

Schedule your independent evaluation

At least once every 3 years, arrange an independent evaluation covering your risk assessment, policy design, actual compliance, and risk mitigation effectiveness. A written report goes to your governing body or responsible senior manager.

V. What It Costs

How much does it cost to get AML/CTF compliant with Klyvon?

Consultant pricing varies by scope, business complexity and provider. Klyvon generates compliance documents from $299/month, ready for review.

Klyvon Essential — Precious Metals & Bullion

$299/month

✓ AML/CTF Program Document
✓ Client Due Diligence Forms
✓ Compliance Officer Letter
✓ SMR Template + Filing Guide
✓ AUSTRAC Enrolment Guide

Get started free →

Month-to-month · cancel anytime · Documents ready for review

VI. Reference

Common questions from precious metals dealers

VII. How Klyvon Helps

Generate your AUSTRAC compliance documents for review

Built for the threshold split

Your program is written around the bullion no-threshold rule and the $10,000 cash threshold — the two-track structure this sector actually runs on.

Cited to current law

Every document cites the AML/CTF Act 2006 and AML/CTF Rules 2025 throughout, kept current as obligations evolve.

SMR drafting included

When suspicion arises, prepare an SMR draft from the information entered for review before submission through AUSTRAC Online.

Get started free →

Free to start · cancel anytime

Primary sources

AUSTRAC — Tranche 2 reform guidance

Last updated 20 August 2026 · Klyvon Compliance Team

Related resources

What is an AML/CTF Program?

Plain English explainer

How to Submit an SMR to AUSTRAC

The 3-day and 24-hour deadlines

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AML/CTF for Accountants

Tranche 2 obligations for accountants

AUSTRAC Penalty Register

Every enforcement action since 2006

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