Tranche 1 · Bullion dealers
AML compliance for bullion dealers
Buying and selling bullion is a designated service. High-value physical transactions demand reliable identity verification, screening and record-keeping that do not obstruct legitimate trade.
Am I captured?
Buying and selling bullion is a designated service.
Designated services include:
- Buying bullion
- Selling bullion
Jewellers and coin dealers may also be captured here or under precious metals and stones, depending on what they actually sell.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. Treat a bullion sale like any other high-value designated service: identify the customer, screen them, and keep the invoice and ID with the lot. Threshold and cash rules still apply.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your bullion business could be used for money laundering or terrorism financing — customers, products, transaction channels and geography — and keep that assessment current as your operations change.
AML/CTF program
Put in writing how your bullion business will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Identity verification, screening and record-keeping around high-value bullion transactions, with the invoice, ID and supporting evidence kept together for audit.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your business — use Trancher within your existing AML/CTF operations, add expert support where needed, or have agreed activities managed for you.
1
Self-managed
Use Trancher within your existing AML/CTF program, with clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with implementation, risk assessment, program updates, onboarding, training or operational reviews.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
Articles for bullion dealers
Bullion Dealer AML: 2026 AUSTRAC Compliance Guide
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Tranche 2 Obligations: 2026 AUSTRAC Readiness Guide
What if the 1 July 2026 deadline wasn’t a threat to your firm’s productivity, but the catalyst for a more profitable advisory model? We know that…
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What Happens During an AUSTRAC Audit? Guide for SMEs
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View article →Questions from bullion dealers
Am I captured?
Bullion dealers have been reporting entities under Tranche 1 when they provide designated bullion dealing services. Obligations depend on the specific services and thresholds that apply.
What are the deadlines?
Tranche 1 obligations have applied for years. Enrolment must be kept current, including nomination of an AML/CTF Compliance Officer. Focus is on ongoing compliance.
What goes in the program?
Your AML/CTF program must include a risk assessment of bullion dealing activity and the controls to manage those risks — customer identification, PEPs/sanctions/adverse media screening, transaction monitoring where relevant, suspicious matter reporting, staff training and record-keeping.
What does CDD look like in practice?
Identify and verify customers as required, screen for PEPs, sanctions and adverse media, and retain records of the checks performed. Higher-value or cash transactions typically attract closer scrutiny.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.