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Tranche 2

Tranche 2 AML Compliance — Impact on Precious Metals Dealers

Why precious metals and stones dealers are exposed to laundering risk, and what AUSTRAC will require once Tranche 2 applies.

Precious metals and stones dealers are among the sectors Tranche 2 brings into Australia's AML/CTF regime — a natural inclusion, given how well the industry's typical transaction profile fits patterns already well known from shell company and cash-based laundering typologies.

Why is this sector specifically vulnerable?

Transactions frequently involve substantial cash or cryptocurrency payments. Second-hand items can change hands with little or no verifiable ownership history. And the stated value of goods can be deliberately misrepresented — inflated or understated — specifically to disguise the transfer of illicit funds through what looks, on paper, like an ordinary sale.

Who actually needs to register with AUSTRAC?

Dealers handling transactions of $10,000 or more in physical currency or digital assets must enrol — a category that includes retail jewellers, stone cutters, manufacturers, miners, refiners, and pawnbrokers, not just high-end luxury retailers. The threshold is what triggers the obligation, regardless of how the business otherwise describes itself.

What does compliance actually require?

A tailored AML/CTF programme built for the business's actual operations, customer due diligence with proper identity verification, screening customers against PEP and sanctions lists, ongoing transaction monitoring rather than a one-off onboarding check, threshold transaction reports (TTRs) for cash transactions over $10,000, suspicious matter reports (SMRs) when warranted, and detailed compliance recordkeeping.

What does implementation actually cost a business in this sector?

Real operational adjustment: financial investment in the right systems, changes to established business practices, staff training on obligations most sector veterans have never had to think about before, and secure recordkeeping infrastructure. AUSTRAC does provide sector-specific guidance, e-learning courses, information sessions, and a dedicated contact centre to help — worth using given how unfamiliar these obligations will be to many businesses in this sector for the first time. See MemberCheck's precious metals industry page for how due diligence and monitoring apply specifically here.

FAQ

Common questions.

Why are precious metals dealers considered vulnerable to laundering?
Transactions often involve large cash or cryptocurrency payments, second-hand items can lack clear ownership history, and the value of goods can be deliberately misrepresented to disguise the transfer of illicit funds.
Which precious metals businesses need to register with AUSTRAC?
Dealers handling transactions of $10,000 or more in physical currency or digital assets, including retail jewellers, stone cutters, manufacturers, miners, refiners, and pawnbrokers.
What compliance obligations apply to precious metals dealers under Tranche 2?
Developing a tailored AML/CTF programme, conducting customer due diligence and identity verification, screening against PEP and sanctions lists, ongoing transaction monitoring, and reporting both threshold transactions over $10,000 and any suspicious matters.
Does AUSTRAC provide support for newly-regulated sectors?
Yes — sector-specific guidance, e-learning courses, information sessions, and a dedicated contact centre are available to help businesses meet their new obligations.

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