Bullion Dealers

Bullion Dealers AML. Compliance Requirements

AML/CTF obligations for bullion dealers in Australia. Learn about customer identification, reporting and compliance requirements.

AML obligations for bullion dealers

According to AUSTRAC, bullion dealers that provide designated services have obligations under the AML/CTF Act due to the money laundering and terrorism financing risks they face.

Buying and selling bullion in the course of carrying on a bullion-dealing business is a designated service requiring customer identification and reporting.

Key requirements

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$5,000 Threshold

Customer ID required for transactions of $5,000 or more.

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Gold, Silver, Platinum

Bullion includes authenticated precious metals in bars, ingots or coins.

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AML/CTF Program

Written program documenting how you identify customers.

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Reporting Obligations

TTRs for $10,000+ cash, SMRs for suspicious activity.

What Counts as Bullion

✓ Included

  • • Gold, silver, platinum, palladium
  • • Bars, ingots, plates, wafers
  • • Bullion coins (0.9166+ purity)
  • • Pool accounts and storage

✗ Not Included

  • • Collector/proof coins (numismatic value)
  • • Industrial-use metals (iridium, rhodium, osmium, ruthenium)
  • • Private sales (not in course of business)

Frequently asked questions

What is considered bullion?

AUSTRAC considers bullion to include gold, silver, platinum or palladium authenticated to a specified fineness, in the form of bars, ingots, plates, wafers, or bullion coins with at least 0.9166 purity.

When do I need to identify customers?

You must identify and verify customers for purchases or sales of bullion when the retail value is A$5,000 or more, or the foreign currency equivalent.

Are collector coins included?

No. AUSTRAC does not consider collector, proof or numismatic coins traded for their collectible value to be bullion - only coins traded by reference to their precious metal market value.

Who counts as a bullion dealer?

Bullion dealers are businesses that buy or sell bullion, including precious metal traders, refiners, jewellers, coin dealers and pawn brokers.

CDD for bullion dealers

ARCaml helps bullion dealers meet customer identification requirements.

✓ Verified

AUSTRAC Aligned

Australia's official AML/CTF regulator standards

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Industry Experts

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Current with 2026 regulations