$10,000 Threshold
AUSTRAC confirms the threshold is $10,000 in physical currency OR virtual assets - not $5,000. CDD required for transactions at or above this value.
Precious Metals Dealers
Bullion Dealer AML Obligations
Comprehensive guide to AML/CTF obligations for dealers in precious metals and bullion under AUSTRAC Tranche 2 reforms. Learn about cash thresholds, reporting requirements, and compliance obligations starting 1 July 2026.
Key Information
AUSTRAC Requirements for Precious Metals Dealers Under Tranche 2
From 1 July 2026, dealers in precious metals, stones, and products become reporting entities under Australia's expanded AML/CTF regime (Tranche 2). AUSTRAC has published detailed guidance on the $10,000 threshold, regulated items, and linked transaction rules.
The $10,000 Threshold (AUSTRAC Confirmed)
AUSTRAC confirms obligations apply when the purchase price of precious metals, precious stones, or precious products equals or exceeds $10,000 in physical currency or virtual assets. This threshold applies to:
- Physical currency (cash) payments
- Virtual asset (cryptocurrency) payments
- Linked transactions that together meet the threshold
What Items Are Regulated? (AUSTRAC Definitions)
Precious Metals:
- Gold, silver, platinum, iridium, osmium, palladium, rhodium, and ruthenium
- Must be in alloy containing at least 2% of that metal
- Includes bars, ingots, coins, and other forms
Precious Stones:
- Gem-quality substances used primarily as adornments
- Includes diamonds, rubies, sapphires, emeralds, and other precious gems
Precious Products:
- Jewellery and watches
- Personal adornments
- Goldsmith wares containing precious metals or stones
Linked Transactions Rule
AUSTRAC warns that you must combine linked transactions when calculating the threshold:
- Layby purchases: Multiple payments toward one purchase
- Structured payments: Payments deliberately split to avoid threshold
- Related transactions: Multiple transactions that form part of a larger arrangement
You must watch for customers deliberately structuring transactions below $10,000 to avoid CDD obligations.
Mixed Sales Rule
When selling a mix of regulated items (precious metals/stones/products) and non-regulated items (regular merchandise):
- Only the precious items count toward the $10,000 threshold
- Regular retail merchandise (clothing, electronics, etc.) is excluded
- If precious items total $10,000+, full CDD obligations apply
Key Compliance Timeline
- 31 March 2026: AUSTRAC enrolment opens
- 1 July 2026: AML/CTF obligations commence
- 29 July 2026: Deadline to complete AUSTRAC enrolment
Your Core Compliance Obligations
- Enrol with AUSTRAC by 29 July 2026
- Develop an AML/CTF program with Parts A and B
- Conduct CDD for transactions at/above $10,000 threshold
- Report suspicious matters to AUSTRAC
- Keep records for at least 7 years
- Monitor for linked transactions and structuring
Key Requirements
Precious Metals Defined
Gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium - in alloy of at least 2% of the metal. Includes bars, ingots, coins.
Precious Stones Defined
Gem-quality substances including diamonds, rubies, sapphires, emeralds. Must be used primarily as adornments.
Precious Products
Jewellery, watches, personal adornments, and goldsmith wares containing precious metals or stones are covered.
Linked Transactions
Layby, structured payments, and split transactions that together meet $10,000 trigger obligations. Watch for deliberate structuring.
Mixed Sales Rules
When selling mix of regulated and non-regulated items, only precious items count toward threshold. Regular merchandise excluded.
Frequently asked questions
What is the transaction threshold for precious metals dealers?
AUSTRAC confirms the threshold is $10,000 in physical currency OR virtual assets (not $5,000 as some have reported). CDD obligations apply when the purchase price of precious metals, precious stones, or precious products equals or exceeds $10,000. This includes payment in cash, cryptocurrency, or other virtual assets.
What precious metals are covered?
AUSTRAC defines precious metals as: gold, silver, platinum, iridium, osmium, palladium, rhodium, and ruthenium - in alloy containing at least 2% of that metal. This covers bars, ingots, coins, and other forms. Items must be made primarily of the precious metal to qualify.
What precious stones and products are regulated?
Precious stones include gem-quality substances used primarily as adornments: diamonds, rubies, sapphires, emeralds. Precious products include jewellery, watches, personal adornments, and goldsmith wares containing precious metals or stones. The definition focuses on items of high intrinsic value.
How do linked transactions work?
Multiple transactions that form part of a larger arrangement count together toward the $10,000 threshold. This includes: layby purchases with multiple payments, structured payments to avoid thresholds, and split transactions between related parties. You must watch for customers deliberately structuring transactions below threshold.
What about mixed sales of regulated and non-regulated items?
When a transaction includes both regulated items (precious metals/stones/products) and non-regulated items (regular merchandise), only the precious items count toward the threshold. If precious items total $10,000+, obligations apply. Regular retail items like clothing or electronics in the same sale don't add to the threshold.
Can virtual assets trigger the threshold?
Yes. AUSTRAC confirms payment in virtual assets (cryptocurrency) counts toward the $10,000 threshold equally with physical currency. A customer paying $10,000 in Bitcoin for gold bullion triggers the same obligations as cash payment.
Prepare for Tranche 2 Compliance
ARCaml provides purpose-built AML/CTF compliance tools for precious metals dealers. Automate customer verification, manage ongoing due diligence, and generate required reports before your obligations commence 1 July 2026.