2026-06-02
Added
Businesses selling precious metals, stones, or products with an Australian geographical link must comply with AML/CTF obligations, excluding transactions paid solely by card or bank transfer. Firms must monitor for linked transactions totaling $10,000 or more using physical currency or virtual assets, considering customer knowledge and transaction patterns. They must submit a suspicious matter report if they suspect structuring to avoid reporting, even if no regulated transaction occurs. Non-compliance carries significant penalties and criminal sanctions for structuring.
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Learn about the new designated services for buying or selling precious metals, stones and products, or a combination of these items, for $10,000 or more in physical currency (cash such as bank notes or coins, whether Australian or foreign currency) or virtual assets.
This section refers to the Act section 6(3).
Whether your business has anti-money laundering and counter-terrorism financing (AML/CTF) obligations depends on the services you provide, known as designated services.
If your business provides one or more designated services that have a geographical link to Australia, you’ll have AML/CTF obligations.
Businesses that buy or sell precious metals, stones or products provide a designated service when they buy or sell these items (or a combination) in the course of carrying on a business, and the purchase or sale satisfies all of the following:
If these items are bought or sold using only a debit or credit card or a bank transfer, the business isn’t providing a designated service.
The relevant designated service defined in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the Act) is extracted below:
Table 2— Precious metals, stones and products
| Item | Provision of a designated service | Customer of the designated service |
|---|---|---|
| 2 | buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products; (d) any combination of any 2 or more of the items referred to in paragraphs (a) to (c) | the buyer or the seller (as the case may be) |
If you provide this designated service you must comply with the Act and Rules. This means you’ll need to enrol with us and meet your AML/CTF obligations.
You must also complete the necessary steps to know your customer before you start to provide them with a designated service. Learn more about initial customer due diligence.
We’ve developed this guidance to describe and support you to meet these obligations.
This section refers to the Act section 5A and Explanatory Memorandum paragraph 336.
Precious metals, stones and products are:
When deciding if a substance outside the above list is a precious stone, we consider that:
It doesn’t matter whether the substance is synthetic, natural or man-made.
Examples of precious products include a:
Personal adornments are items that can be worn by a person to add beauty or interest to an outfit. Personal adornments will be precious products if they contain, or have attached to them, any precious metals or stones. Examples include:
Goldsmiths or silversmiths’ wares broadly capture products crafted from a precious metal and made or sold by goldsmiths or silversmiths. Examples include tableware, trophies, goblets and ornamental items and other articles of personal, household, office or religious use.
This section refers to item 2 of table 2 in section 6 and section 142 of the Act. It also refers to the to the Explanatory Memorandum paragraph 340.
You’ll provide a regulated transaction if all the following apply:
If you accept linked payments that total $10,000 or more, you must treat the service as regulated and comply with AML/CTF obligations.
Therefore, even if you only accept physical currency and/or virtual assets for transactions less than $10,000, you must have processes in place to monitor for and identify linked or apparently linked transactions that could reach the $10,000 threshold.
Learn more about what to do if you accept physical currency and/or virtual assets of less than $10,000 per transaction at regulation options for dealers in precious metals, stones and products.
Linked transactions are payments, sales or purchases that are connected where you sell or purchase precious metals, stones or products (or a combination of these) in the course of carrying on a business.
They might involve the same customer, similar items or happen close together. They can also include legitimate uses or be used to avoid AML/CTF reporting.
To identify if transactions are linked, ask yourself whether the transactions:
When identifying linked transactions, we expect you to consider both:
See more examples of transactions that are linked or appear to be linked in practice.
Structuring is a type of linked transaction and is a common money laundering technique. It happens when someone divides large physical currency transactions into smaller ones to avoid threshold transaction reporting obligations, which activate when you accept a physical currency transaction valued at $10,000 or more.
Structuring to avoid reporting is a criminal offence. Signs of structuring might include:
If you accept linked transactions reaching the $10,000 threshold or more, you must monitor for unusual transactions and behaviours. This includes monitoring for structuring.
You must submit a suspicious matter report (SMR) if both:
You must also submit an SMR if all of the following are satisfied:
This applies even if you don’t accept the cash or virtual asset transaction giving rise to the suspicious matter.
Your customer wants to buy $30,000 worth of uncut diamonds in cash. Your business normally accepts transactions over $10,000 in cash.
When discussing payment, they suggest paying $9,000 now and return over several days to make further cash payments under $10,000. They ask if you can treat each payment as a separate transaction.
When you ask why, they avoid the question and repeat that they prefer to pay this way.
This gives you reasonable grounds to suspect the customer is structuring to avoid threshold transaction reporting.
You must submit a suspicious matter report. This applies even if you do not accept the cash transaction giving rise to the suspicious matter.
Learn more about:
You start providing a designated service from the time that all of the following are satisfied:
If your customers can make purchases from you, or sales to you, using physical currency or virtual assets, you may inadvertently provide a designated service.
For example, your customer may purchase a single item worth $15,000 and pay for it over multiple instalments:
While each individual transaction is below the $10,000 threshold of the designated service, they’re transactions that are linked or appear to be linked, so are combined. This means the business begins providing a designated service on day 2.
If only part of the sale involves regulated items, the value of those items must be $10,000 or more for there to be a designated service.
Where a transaction, or multiple transactions that are linked or appear to be linked, involve a mix of regulated and unregulated items, only regulated items will be counted towards the $10,000 threshold.
For example, a shop sells a customer $11,500 of items in a single transaction, which includes:
This purchase isn’t a designated service, because the value of the regulated item (belt buckle) alone is valued under $10,000.
If your business provides this designated service, we expect you to do all of the following:
You must discharge a range of AML/CTF obligations before you start to sell or buy an item or items regulated under this designated service. This includes identifying your customer and developing and implementing an AML/CTF program.
If your business doesn’t adopt the transaction detection systems mentioned, there’s a significant chance that your business won’t identify these transactions and discharge your AML/CTF obligations in relation to them within the required timeframes. Non-compliance with these obligations carries significant penalties.
This risk is magnified when dealing with transactions that are linked or appear to be linked. Many of these transactions, particularly transactions deliberately structured under the $10,000 threshold, will be difficult to detect without establishing dedicated processes.
This guidance sets out how we interpret certain Australian legislation, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened.
The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.
This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.
Last updated:
10 Jul 2026
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Source: Australian Transaction Reports and Analysis Centre — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works