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ML/TF risk assessment for Precious metals & stones dealers — 2026 AUSTRAC Guide

From 1 July 2026, dealers in precious stones, metals and related products who provide a designated service must have a written ML/TF risk assessment. This applies because your sector is regarded by AUSTRAC as highly exposed to money laundering risk, particularly where high-value goods can be bought, resold, concealed, moved and converted back into funds. If you do not do it properly, you risk breaching the AML/CTF Act, which can lead to AUSTRAC enforcement, civil penalties of up to $33.5 million per contravention, and criminal penalties for intentional contraventions.

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 risk assessment is the foundation of your AML/CTF program. It must be a written document that identifies and rates the money laundering, terrorism financing and proliferation financing risks in your business across four areas: your customers, the designated services you provide, the way you deliver those services, and the countries connected to your customers or transactions. You must complete it before you finalise your AML/CTF program, and your program must be finalised by 31 December 2026.

How to complete the risk assessment

  • List the designated services you actually provide. Do not assess your whole business at a high level — focus on the specific services that trigger AML/CTF obligations.
  • Map where your exposure sits: high-value jewellery, luxury watches, loose stones, custom pieces, second-hand items, and any transactions involving large value movements or overseas connections.
  • Rate risks for each category AUSTRAC expects you to assess: customers, services, delivery channels and geography.
  • Document why a risk is low, medium or high. For example, cash-heavy sales, customers using third parties, remote onboarding, or links to high-risk jurisdictions should push the rating up.
  • Use the finished assessment to build your AML/CTF policies, procedures, systems and controls, then update it whenever your business changes materially.

Sector-specific risk areas

AUSTRAC says the retail jewellery sector poses a high money laundering risk in Australia. For this sector, obvious pressure points include customers wanting anonymity, rapid purchase and resale of valuable items, under- or over-valuation, suspiciously high-volume buying, structuring under reportable cash amounts, payment through unregulated platforms, and international movement of value.

For precious metals and stones dealers, a generic template is not enough. Your assessment should reflect how criminals may use your stock: items can be bought readily, concealed easily, altered, melted, refined, moved offshore, or sold again to make illicit money look legitimate. If you deal with customers connected to military arms, munitions or dual-use goods, or with jurisdictions of proliferation concern, you also need to assess proliferation financing risk and decide whether you need specific controls for that risk.

Common mistakes and practical tips

  • Do not confuse the risk assessment with AUSTRAC enrolment. Enrolment is separate and must be done via AUSTRAC Online.
  • Do not assess only cash risk. Electronic payments can still be high risk even though they do not trigger threshold transaction reports.
  • Do not ignore delivery channel risk. Online sales, phone orders, agents, couriers and dealings without face-to-face contact usually need closer scrutiny.
  • Build controls that match your trading reality: unusual purchase monitoring, extra checks on bulk or repeat purchases, sanctions screening, and stronger review of funds from unknown or overseas sources.
  • Review the document whenever you materially change the business, such as adding online sales, dealing in new products, accepting international customers, or expanding into bullion-related activity.

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Frequently asked questions

Do I need a risk assessment if I only sell jewellery in-store and never send goods overseas?
Yes, if you provide a designated service. Operating only in Australia may reduce your geography risk, but it does not remove the obligation. AUSTRAC still expects you to assess customer, service and delivery channel risks, including high-value purchases, cash use, resale potential and anonymity concerns.
What if I sell low-value items most of the time but occasionally sell a very expensive watch or diamond piece?
Your assessment should reflect both your usual business and your higher-risk exceptions. A business with occasional high-value transactions may still have a significant ML risk because those sales are attractive to criminals. Document the higher-risk scenarios and the extra controls you apply when they happen.
Can I just buy a template and fill in a few details?
You can use a template as a starting point, but it must be tailored to your actual business. A generic document that does not deal with your products, customer types, payment methods, remote sales, overseas links or volume patterns is unlikely to be adequate. AUSTRAC expects the assessment to be specific to your size, services and risk profile.
Does this assessment have to cover proliferation financing even if I only deal in jewellery?
Yes. Your written assessment must consider proliferation financing risk as part of your ML/TF risk assessment. If your exposure is genuinely low, your existing AML/CTF policies may be enough, but you still need to assess and record that conclusion.
How much should a small dealer expect to spend on doing this properly?
The Act does not set a required spend. A small dealer with a simple in-store model may be able to do much of the work internally if they understand their designated services and document risks properly, while more complex businesses may need external help. The real requirement is not cost but whether the written assessment accurately identifies and rates the risks in your business.

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