Tranche 2 · Precious metals & stones

AML compliance for dealers in precious metals and stones

Dealers buying or selling precious metals, stones or products (or combinations) at or above the cash/virtual asset threshold are reporting entities. Cash-intensive and high-value transactions require robust CDD and record-keeping without slowing legitimate trade.

Am I captured?

Dealers buying or selling precious metals, stones or products (or combinations) at or above the cash or virtual-asset threshold are reporting entities.

Designated services include:

  • Buying or selling precious metals, precious stones or precious products at or above the prescribed cash or virtual-asset threshold
  • Combinations of those goods that together meet the threshold

Occasional private sales below the threshold are generally not.

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. High-value and cash-intensive trades are exactly why this sector was brought in. Identify the customer before the goods leave, and keep the invoice, ID and any source-of-funds notes with the sale.

01

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.

02

Risk assessment

Document how your firm could be used for money laundering or terrorism financing — clients, services, delivery channels and geography — and keep that assessment current as the practice changes.

03

AML/CTF program

Put in writing how the firm 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.

04

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.

05

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.

06

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

Support customer identification, screening and source-of-funds records around high-value transactions, with the invoice, ID and compliance evidence kept together for an audit-ready trail.

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 — manage compliance yourself, add expert support when you need it, or have agreed activities managed for you.

1

Self-managed

Run your AML program through Trancher using 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 set-up, risk assessment, program development, onboarding, training or first files.

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.

  1. Days 1–7

    Enrolment and risk assessment underway

  2. Days 8–21

    Workflows live and team trained

  3. Thereafter

    Fully operational and audit-ready

Questions from precious metals and stones dealers

Am I captured?

Dealers buying or selling precious metals, stones or products (or combinations) at or above the prescribed cash or virtual-asset threshold are reporting entities. Occasional private sales below the threshold are generally not captured.

What are the deadlines?

Tranche 2 obligations commenced on 1 July 2026. Dealers already providing designated services on that date needed to enrol with AUSTRAC by 29 July 2026. If you start providing a designated service later, enrol within 28 days of first providing it. Nominate an AML/CTF Compliance Officer and keep your enrolment current.

What goes in the program?

Your AML/CTF program must include a written risk assessment focused on high-value and cash-intensive trades, plus the controls to manage those risks. This typically covers customer identification before goods leave the premises, source-of-funds notes where relevant, PEPs/sanctions/adverse media screening, suspicious matter reporting, staff training and retention of the invoice, ID and compliance evidence together.

What does CDD look like in practice?

Identify the customer before the goods leave, verify identity, and screen for PEPs, sanctions and adverse media. Source-of-funds questions are relevant on higher-value or cash transactions. Keep the invoice, identification records and any source-of-funds notes with the sale so the evidence is available for audit.

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.