AML Compliance Guide
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Staff training for Precious metals & stones dealers — 2026 AUSTRAC Guide

From 1 July 2026, if your jewellery, precious metals, stones or luxury watch business provides a designated service, you must train the people in your business who deal with customers or handle those transactions on your AML/CTF obligations. This applies because your sector is considered high risk for money laundering, especially where high-value goods can be bought, moved, resold, remodelled or paid for in ways that hide the source of funds. If you do not train staff properly, you increase the risk of missed red flags, sanctions breaches and reporting failures, and AUSTRAC can take enforcement action with 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

For a precious metals and stones dealer, staff training is not a one-off slideshow. Your AML/CTF program must set out who needs training, what they need to know, how often they must be trained, and how you will record it. Training must be tailored to the person’s role. A sales assistant taking payment for a high-value diamond necklace needs different training from the person onboarding trade buyers, approving unusual transactions, handling international payment instructions or reviewing suspicious behaviour. AUSTRAC expects training to be understandable, accessible and specific to your business, your products and your risks.

What you need to do

  • Identify which roles in your business perform AML/CTF functions: customer-facing sales staff, onboarding staff, managers approving transactions, anyone handling international transfers, and anyone responsible for monitoring or escalation.
  • Build role-based training into your AML/CTF program before 31 December 2026, including content, delivery method, refresher timing, record keeping and who signs off on completion.
  • Train relevant staff on your actual risks: high-value cash purchases, attempts to split cash payments, use of third parties, rushed purchases of portable items, requests to undervalue goods, unusual export or delivery instructions, and customers wanting anonymity.
  • Keep records of who was trained, when, what they completed, and when retraining is due. Repeat training when your program changes, when laws or AUSTRAC guidance change, or when you identify gaps or breaches.

Minimum timing to build into your schedule

Customer-facing personnel should generally be retrained every 12 months. Personnel responsible for onboarding, transaction monitoring or enhanced CDD roles should also generally be retrained every 12 months. AML/CTF compliance officers and senior management should generally receive training every 6 to 12 months. Third-party vendors should be trained when onboarded and when the contract is renewed or changed.

Your training should focus on the situations your staff will actually face on the shop floor or in trade dealing. They need to know that a threshold transaction report is only triggered by physical cash of $10,000 AUD or more, not cards, EFT or cheques. They also need to spot structuring, where a customer tries to split cash payments to avoid the threshold. Staff should be trained to identify politically exposed persons for enhanced due diligence, screen customers against DFAT and UN sanctions lists before and during the relationship, and escalate suspicious conduct without telling the customer. Tipping off is a separate criminal offence.

Common training mistakes in this sector

  • Using generic online AML training that never mentions jewellery, loose stones, scrap precious metal, luxury watches or trade-ins.
  • Training only permanent staff and ignoring casual sales staff, showroom staff, buying agents, workshop staff involved in customer transactions, or third parties acting for you.
  • Teaching the cash reporting rule incorrectly by including EFT, card or cheque payments as TTRs.
  • Failing to train staff on suspicious pricing, anonymous resale behaviour, requests to melt or alter items quickly, or delivery instructions that do not make commercial sense.

Keep the training practical. Use examples from your own business: a customer wanting to buy several smaller gold items in separate cash payments, a buyer insisting on immediate collection by a different person, or a foreign customer asking for shipment to a high-risk jurisdiction. AUSTRAC’s e-learning can help, but it cannot be your only training because your staff must understand your own procedures, escalation path, and product-specific risks. For a small dealer, the simplest workable approach is a short induction module for all new staff, annual role-based refreshers, and quick update sessions whenever your risks, procedures or AUSTRAC guidance change.

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Frequently asked questions

Do I need to train every employee, or only the people who sell jewellery and precious metals?
You must train all staff who deal with customers or handle relevant transactions, and your AML/CTF program should identify which roles perform AML/CTF functions. Customer-facing sales staff, onboarding staff, managers approving unusual transactions and anyone involved in international transfer instructions need role-specific training. Staff not in AML/CTF-relevant roles should still receive general awareness training at onboarding.
Can I just use AUSTRAC’s e-learning modules and leave it at that?
No. AUSTRAC’s e-learning modules can be used as part of your training, but they cannot be relied on solely to meet your obligation. You must tailor training to your business, your products, your ML/TF risks and the person’s responsibilities under your AML/CTF policies.
We are a small family-run jewellery business with casual weekend staff. Do casuals need AML training too?
Yes, if they deal with customers or take part in designated services. Casual staff can be the first to see suspicious cash behaviour, structuring attempts or unusual urgency around high-value portable goods, so they need training that matches their role. Keep it short and practical, but document it properly.
Can I outsource training to an industry association or external provider?
Yes, you can outsource delivery of training to a third party, but you remain responsible for making sure it is appropriate, understandable and tailored to your business. You should check the provider’s expertise, make sure the content reflects the risks in precious metals and stones dealing, and supplement generic material with your own procedures and examples.
What should I do if a staff member misses suspicious behaviour because they were not trained properly?
Retrain them as soon as practicable and review whether the issue shows a wider gap in your AML/CTF program. You should also update training content, document what happened, and assess whether the conduct should have been escalated for an SMR or another report. If the failure exposed a sanctions, reporting or CDD breach, treat it urgently.

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