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AML/CTF program for Precious metals & stones dealers — 2026 AUSTRAC Guide

If your business provides a designated service as a dealer in precious metals, stones and products from 1 July 2026, you must have a written AML/CTF program. For this sector, that means documenting how you will identify and manage the money laundering, terrorism financing and proliferation financing risks linked to high-value, portable goods that can be bought, resold, concealed or moved offshore. If you do not finalise and maintain a compliant program, AUSTRAC can take enforcement action and civil penalties can reach $33.5 million per contravention, with criminal penalties for intentional breaches.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

Your AML/CTF program is not a template you download and forget. It is the written system your business will actually follow before you sell, arrange, or otherwise provide a designated service involving precious metals, stones or relevant products. It has two parts: first, your written ML/TF risk assessment; second, your policies, procedures, systems and controls to manage those risks. For a jewellery store, watch dealer, second-hand luxury goods business or workshop dealing in precious metal items, the program should reflect the real risks AUSTRAC has flagged for this sector: high-value items, anonymous purchasing attempts, portability, resale value, under- or over-valuation, and customers trying to use cash or complex ownership structures.

Deadline and sequence

You must complete your ML/TF risk assessment before you finalise your AML/CTF program. Newly regulated businesses must enrol with AUSTRAC by 29 July 2026 if they are operating on 1 July 2026, and the AML/CTF program must be finalised by 31 December 2026.

How to build the program for a precious metals or stones business

  • Map your designated services first. Do not assume every sale is covered. Work out exactly which transactions or service types in your business trigger AML/CTF obligations.
  • Write your ML/TF risk assessment. Rate risks across customer types, products, delivery channels and geography. Include risks such as high-value jewellery, luxury watches, loose stones, overseas customers, agents acting for others, and unusual payment methods.
  • Set your operating rules in writing. Document when staff must do customer due diligence, how beneficial owners are identified for companies and trusts, when enhanced due diligence applies, and when a matter must be escalated.
  • Build controls around sector-specific red flags. Include procedures for unusual valuations, rapid resale patterns, requests to split purchases, use of third parties, reluctance to provide ID, and attempts to transact near reporting thresholds.
  • Get senior management approval, train staff, and keep the program current. If you add online sales, start sourcing from new countries, begin dealing in different products, or change how you accept payments, update the risk assessment and program.

A common mistake in this sector is treating the AML/CTF program as only a cash-reporting document. It is much broader than threshold transaction reports. Electronic payments do not trigger TTRs, but your program still needs controls for suspicious activity, customer due diligence, sanctions screening, beneficial ownership checks and record keeping. Another mistake is using a generic retail policy that says nothing about precious metals or stones. AUSTRAC has specifically identified this sector as highly exposed to money laundering because these goods are easy to move, conceal, reshape and convert back into legitimate funds. Your program should show that you understand those risks in your own stock mix and sales model.

Practical tips for small dealers

  • Create a product risk table for bullion-related items, jewellery, luxury watches, loose stones and custom pieces so staff know which sales need closer review.
  • Use a simple transaction review form for large or unusual purchases, including who the customer is, why they want the item, payment method, and whether anyone else is behind the transaction.
  • Set clear approval points for higher-risk matters, such as foreign customers, politically exposed persons, trust buyers, or anyone wanting to buy through a company with unclear ownership.
  • Keep valuation records, invoices, ID checks, trust deeds and ASIC searches together so you can support your decisions and retain the records for 7 years after the relationship ends.

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Frequently asked questions

Do I need an AML/CTF program if I only sell jewellery and watches through a shopfront?
If you provide a designated service, yes. The fact that you trade from a physical store does not remove the obligation. The first step is to confirm which parts of your business are designated services, because not every activity of a precious metals or stones dealer is automatically covered.
Can I use AUSTRAC's starter kit and leave it at that?
You can use a starter kit as a base, and AUSTRAC has released sector-specific starter kits to help smaller businesses. But you still need to tailor the program to your own business. A store selling custom diamond pieces, pre-owned watches and occasional loose stones will not have the same risk profile as a small regional jeweller selling low-value stock only.
What if most of my customers are long-term local customers I already know personally?
You still need a written AML/CTF program if you provide a designated service. Familiarity with customers does not replace a documented risk assessment, CDD rules and reporting procedures. Your program can reflect that some customers are lower risk, but it still needs a process for new, unusual or higher-risk dealings.
How much will it cost to put an AML/CTF program in place?
AUSTRAC enrolment is free, but building the program will still take time and usually some cost. The main expense for a small dealer is usually staff time to map designated services, write the risk assessment, set procedures, train staff and keep records. Costs rise if your ownership structures, online sales channels or international dealings are more complex.
What if my business changes after I finish the program?
You must update the ML/TF risk assessment whenever the business changes materially, and then update the program to match. For this sector, that could include starting online sales, accepting new payment methods, expanding into higher-value stock, dealing with overseas customers, or adding a second location.

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