AML Compliance Guide
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Record keeping (7 years) for Precious metals & stones dealers — 2026 AUSTRAC Guide

If you provide a designated service as a precious metals or stones dealer from 1 July 2026, you must create and keep AML/CTF records for 7 years. For this sector, that means keeping enough detail to reconstruct high-value sales, purchases, transfers and customer instructions involving jewellery, loose stones, precious metal items or other covered products. If you do not keep proper records, AUSTRAC can treat that as a breach in its own right, with civil penalties up to $33.5 million per contravention, and criminal penalties can apply 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

This obligation is broader than just filing paperwork away. You must keep three main kinds of records: your AML/CTF program records, your customer due diligence records, and transaction records related to each designated service. AUSTRAC’s guidance says transaction records must contain enough detail and supporting documents to fully and accurately reconstruct the transaction. For a precious metals or stones dealer, that can include the date and time of sale, item description, amount and currency, customer name and identifiers, payment method, invoices, receipts, contracts, valuation documents, transfer instructions and any related documents the customer gave you.

What you should do in practice

  • Create a record-keeping policy that states what records you keep, where they are stored, who is responsible, how long they stay on file, and how you protect them.
  • For every designated service, keep a complete transaction file: invoice, receipt, item description, serial number or hallmark if relevant, weight, purity, stone details, payment method, and customer-supplied documents such as signed order forms or payment instructions.
  • Keep your CDD records for each customer, including ID checks for individuals and entity documents for companies or trusts, plus any beneficial owner information you collected.
  • Store records in English, or in a format that can be easily translated into English, and make sure they are easy to retrieve if AUSTRAC asks for them.
  • Retain AML/CTF program documents and CDD records for 7 years after the business relationship ends, and transaction records for at least 7 years from when the record is created or the transaction is completed.

Retention periods are not all counted the same way

CDD records are kept for at least 7 years after the customer relationship ends. General transaction records are kept for 7 years from the day the record is created, and customer-provided transaction documents are kept for 7 years from the day the customer gave them to you. If you mix these up, you can destroy records too early.

Common mistakes in this sector usually come from treating AML/CTF records like ordinary retail paperwork. A point-of-sale receipt on its own is rarely enough if it does not identify the specific item sold or the customer tied to the designated service. Another mistake is keeping a copy of the invoice but not the supporting documents that explain the transaction, such as a bespoke jewellery order, a buy-back agreement, remodelling instructions, shipping paperwork or customer payment instructions. If your business deals in high-value items that can be easily moved, melted, remodelled or resold, AUSTRAC will expect records that show exactly what happened and who was involved.

Practical tips for precious metals and stones dealers

  • Use stock numbers or unique transaction identifiers to link the customer file, invoice, workshop job sheet and payment record.
  • Record item-specific details such as metal type, purity, weight, gemstone type, carat, certificate number, watch serial number or other distinguishing features.
  • Keep copies of text messages, chat app instructions or email directions if a sale, hold, alteration or transfer was arranged that way.
  • Restrict access to sensitive files, especially CDD records and suspicious matter reporting material, and back up electronic records to secure offsite or encrypted cloud storage.
  • Train sales staff and workshop staff on what must go into the file when a transaction involves a designated service, not just what is needed to complete a sale.

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Frequently asked questions

Do I have to keep records for every sale in my store?
You must keep records for each designated service you provide, not automatically every service your business offers. Whether a sale is a designated service depends on the AML/CTF Act and the type of activity you are carrying on. If a transaction falls within your designated services, keep a full file that lets AUSTRAC reconstruct what happened.
Is my normal POS receipt enough to meet the record-keeping rules?
Usually not by itself. AUSTRAC expects transaction records to include enough detail and supporting documents to fully and accurately reconstruct the transaction. For a jewellery or precious metal transaction, that often means the receipt plus the invoice, item description, customer details, payment method and any signed instructions or agreements.
What if the customer gives me documents by email or text message?
You must keep customer-provided transaction documents, and that includes documents or instructions given while you are providing the designated service. If the customer sends payment instructions, order details or signed forms by email, text or another app, save them into the transaction file. Make sure they remain retrievable for 7 years.
Can I store everything electronically, or do I need paper files?
Electronic storage is fine if the records are secure, complete and easy to retrieve. Your system should protect records from unauthorised access, loss or tampering, and you should back up files to secure offsite or encrypted cloud storage. If records are not originally in English, you must be able to translate them quickly into English.
Will this be expensive for a small dealer, and what is the minimum workable setup?
You do not need a complex enterprise system, but you do need a reliable process. A practical setup for a small dealer is a written record-keeping policy, a structured digital folder system linked to stock or invoice numbers, secure cloud backup, restricted staff access and a checklist for each designated service file. The cost of setting this up is usually far lower than the risk of missing records in an AUSTRAC review.

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