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Sanctions screening for Precious metals & stones dealers — 2026 AUSTRAC Guide

From 1 July 2026, a precious metals and stones dealer that provides a designated service must screen customers against Australia’s sanctions lists before the sale or other designated service goes ahead, and keep screening during the relationship. This matters in your sector because high-value jewellery, diamonds, watches and other precious goods can be used to store and move value quickly. If you provide a service to a sanctioned person, you can commit a strict-liability criminal offence, and broader AML/CTF breaches can also attract civil penalties of up to $33.5 million per contravention.

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

Sanctions screening is separate from ordinary customer identification. Checking a driver licence or company details does not tell you whether the customer is subject to Australian sanctions. Your job is to screen all customers against the DFAT autonomous sanctions list and the UN Security Council consolidated list before you provide the designated service, then rescreen during the relationship if you have an ongoing customer or the customer details change. For a dealer, that means screening before you complete a covered transaction involving precious metals, precious stones or relevant products, not after you have handed over the goods.

What to do in practice

  • Work out which of your services are designated services. AML/CTF does not attach to every sale you make, so confirm which transactions trigger reporting entity obligations.
  • Collect the customer details you need for screening before the transaction is completed: full name for an individual, and for entities the legal name plus key ownership and control details where relevant.
  • Screen the customer, and where applicable beneficial owners or controllers, against the DFAT autonomous sanctions list and the UN Security Council consolidated list before providing the service.
  • If you get a possible match, stop the transaction and review it carefully. Do not release the jewellery, stones, metal or other product until the match is resolved.
  • If you form reasonable grounds to suspect something is wrong, consider whether you also need to lodge a suspicious matter report with AUSTRAC within 3 business days, or within 24 hours if terrorism financing is suspected.
  • Keep records of the screening result, what list was checked, the date checked, any escalation steps, and the final decision. Keep those records for 7 years after the relationship ends.

Critical warning

Providing services to a sanctioned person is a strict-liability criminal offence. Do not tell the customer you are filing or considering an SMR if the matter becomes suspicious. Tipping off is a separate criminal offence.

The biggest mistake in this sector is assuming sanctions screening only matters for overseas buyers or shipments leaving Australia. It applies to customers anywhere if you are providing the designated service in Australia. Another common mistake is screening only the person standing at the counter. If a company, trust or nominee is buying, you need to understand who ultimately owns or controls it. High-risk situations for dealers include unusual interest in portable high-value items, complex ownership structures, rushed purchases, requests to use third parties, and customers linked to high-risk countries. PEPs and other high-risk customers need enhanced due diligence as well as sanctions screening.

Practical tips for jewellery and precious goods dealers

  • Build screening into the sales process before final payment and before goods are released, especially for custom orders, lay-bys, consignments and high-value stones.
  • Train floor staff and account managers to pause a transaction when names do not match cleanly or when a company buyer has unclear ownership.
  • Use a simple escalation rule: no screening result, no completed designated service.
  • Rescreen repeat trade customers, wholesale buyers and overseas-linked clients whenever ownership, controllers or trading names change.
  • Keep a written script for staff so they can ask for extra information without mentioning sanctions, SMRs or AUSTRAC reporting.

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Frequently asked questions

Do I need to screen every walk-in customer who buys jewellery or a watch?
You need to screen every customer before providing a designated service. Not every sale made by a precious metals and stones dealer is necessarily a designated service, so first work out which parts of your business are captured. Once a transaction is a designated service, screening is not optional just because the customer is a walk-in retail buyer.
What if the customer is an Australian company rather than an individual?
Screen the company name, and do not stop there. You also need to understand who ultimately owns or controls the entity, because beneficial owners and controllers can create sanctions risk even where the company name itself does not match a list. For companies and trusts, unclear ownership is a reason to pause and ask more questions.
Do I only need to screen overseas customers or exports?
No. Sanctions screening is not limited to exports or foreign buyers. A customer in Australia can still be a sanctioned person, and your obligation is to screen before providing the designated service and during the relationship where it continues.
What should I do if a customer name is close to a sanctions match but not exact?
Do not complete the transaction until you have resolved it. Check other identifiers you hold, such as date of birth, address, company details or ownership information, and escalate internally for review. If the circumstances become suspicious, you may also need to file an SMR with AUSTRAC.
Do I have to buy expensive screening software?
The law requires effective screening, not a particular brand of software. A small dealer can use a manual or low-cost process if it is reliable, documented and built into the transaction workflow before goods are released. What matters is that all customers for designated services are screened against the DFAT autonomous sanctions list and the UN Security Council consolidated list, and that you can prove you did it.

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