AML Compliance Guide
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Deadline: 29 July 2026 — enforcement now active

Compliance officer for Precious metals & stones dealers — 2026 AUSTRAC Guide

If your jewellery, precious metals, stones or related products business will provide a designated service from 1 July 2026, you need to nominate a compliance officer as part of getting your AML/CTF arrangements in place. For a small dealer, this is usually the owner, director or another senior person who can make decisions, keep the program moving and deal with AUSTRAC requirements. If you ignore this step and your business falls under the regime, you risk being unable to properly implement your AML/CTF program and wider obligations, exposing the business to serious enforcement action, civil penalties of up to $33.5 million per contravention, and 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

For a precious metals and stones dealer, the compliance officer is the person inside the business who takes responsibility for day-to-day AML/CTF oversight. In practice, that means making sure your shop or trading business knows when it is providing a designated service, enrols with AUSTRAC on time, builds the ML/TF risk assessment, finalises the AML/CTF program, and makes sure staff follow customer identification, sanctions screening, suspicious matter reporting and record-keeping rules. In a small jewellery business, this role does not need to be a separate full-time hire, but it does need to be clearly assigned to someone with enough authority to change processes and stop risky sales or transactions.

Deadline that matters now

If you are a newly regulated dealer already operating on 1 July 2026, you must enrol with AUSTRAC by 29 July 2026 through AUSTRAC Online. Appointing the person who will handle compliance should be done before then, because enrolment is your first mandatory step and your AML/CTF setup will stall without a responsible person driving it.

What to do in your business

  • Work out whether you provide a designated service, rather than assuming every jewellery or precious metal sale is regulated.
  • Choose a compliance officer who understands your cash sales, custom orders, buy-back activity, repairs linked to asset transfers, and any international dealings.
  • Give that person authority to collect customer ID, stop a transaction, escalate suspicious behaviour and keep records for 7 years.
  • Set up a simple reporting line so floor staff, sales staff and workshop staff know who to contact if a customer wants to pay unusual amounts in cash or behaves suspiciously.
  • Record the appointment in writing and make the compliance officer responsible for coordinating enrolment, the risk assessment and staff training.

Common mistakes in this sector usually come from treating AML/CTF as just a back-office formality. Dealers often assume the store manager can 'look after compliance' without formally assigning responsibility, or they leave it to an external bookkeeper who does not see customer behaviour in the shop. Another mistake is focusing only on large cash transactions. AUSTRAC has identified the retail jewellery sector as high risk for money laundering because precious jewellery, watches, stones and metals can be bought, sold, concealed, reworked and converted back into funds. Your compliance officer needs visibility over customer conduct, unusual purchase patterns, requests to split payments, third-party payments, rapid resales, and dealings involving offshore connections.

Practical tips for jewellers and dealers

  • In a single-store business, the owner or director is usually the most sensible compliance officer because they can approve procedures and intervene immediately.
  • Keep a written escalation checklist at the counter for staff: ID issues, sanctions match, attempted structuring of cash, third-party payer, rush to buy high-value items, or reluctance to explain source of funds.
  • Make your compliance officer review sales channels separately: in-store sales, phone orders, online orders, consignments and overseas shipments create different risks.
  • If you deal in high-value watches, diamonds or scrap precious metal, make sure the compliance officer understands valuation and resale risks, not just retail sales processes.

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Frequently asked questions

Do I have to hire a separate compliance officer for my jewellery business?
No. In a small precious metals or stones business, the compliance officer will often be the owner, sole director or a senior manager. What matters is that the person has enough authority and time to run the AML/CTF process properly.
Can my external accountant or consultant be my compliance officer?
They can help you build documents and systems, but relying on an external adviser alone is risky because they do not see what happens with customers in your store or workshop. You still need someone in the business who can make decisions, supervise staff and respond immediately to suspicious activity.
If I only sell jewellery and accept card payments, do I still need a compliance officer?
You need to first check whether the service you provide is a designated service. AML/CTF obligations apply to designated services, not automatically to every jewellery sale. If your business is regulated, you need a person responsible for compliance even if cash is rare.
Does appointing a compliance officer have to be done by 29 July 2026?
The hard legal deadline on 29 July 2026 is for AUSTRAC enrolment if you are a newly regulated business operating from 1 July 2026. In practice, you should appoint your compliance officer before enrolment so someone is accountable for getting that step done and coordinating the rest of your setup.
What will this cost a small dealer?
Appointing the person itself does not involve an AUSTRAC fee, and AUSTRAC enrolment is free. Your real cost is staff time, training, documenting procedures and, if you choose, paying for outside help to build your risk assessment and AML/CTF program.

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