Tranche 2 deadline: 1 July 2026—40 days remaining
AML/CTF Compliance · Jewellers & Precious Metals Dealers
AML/CTF Compliance for Jewellers and Precious Metals Dealers
From 1 July 2026, jewellers, precious metals dealers, precious stones dealers, and pawnbrokers in Australia must comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) under the Tranche 2 reforms. If your business sells or purchases precious metals, precious stones, or precious products and accepts cash or virtual asset payments of $10,000 or more, you are a reporting entity and must enrol with AUSTRAC by 29 July 2026. Bullion dealers are regulated at any value regardless of payment method.
Built on AUSTRAC official guidance · AI-generated · Firm-specific · No legal knowledge required · Ready in 60 seconds
Scope questions
Does my jewellery business need to comply with AUSTRAC?
Yes, if your business sells or purchases precious metals, precious stones, or precious products and accepts cash or virtual asset payments of $10,000 or more in a single transaction or linked transactions, you are a reporting entity. Source: AUSTRAC — Dealers in precious metals, stones and other products ↗; AML/CTF Act 2006, as amended by the AML/CTF Amendment Act 2024.
Businesses with a clear, documented policy prohibiting acceptance of cash or virtual asset payments of $10,000 or more — and that strictly enforce it — may not be regulated for precious metals transactions. However, bullion dealers are regulated at any transaction value and through any payment method.
What counts as a precious product under AUSTRAC rules?
Precious products include jewellery, watches, and items of personal adornment made of or containing precious metals or stones. Precious metals include gold, silver, platinum, palladium, iridium, osmium, rhodium, and ruthenium. Precious stones include diamonds, opals, pearls, sapphires, and garnets.
Source: austrac.gov.au ↗
Is bullion regulated differently to jewellery under AUSTRAC?
Yes. Bullion — gold, silver, platinum, or palladium in bar, ingot, or wafer form — is a separate designated service regulated at any transaction value and through any payment method, not just cash over $10,000. If you sell bullion, you are a reporting entity regardless of how your customers pay.
What if I only accept card payments — am I still regulated by AUSTRAC?
If you have a clear, documented business policy never to accept cash or virtual asset payments of $10,000 or more and strictly enforce it, you may not be regulated for precious metals transactions. AUSTRAC recommends documenting this policy explicitly in writing, including staff instructions. Bullion dealers remain regulated regardless of payment method.
Do pawnbrokers need to comply with AUSTRAC?
Yes. Pawnbroking is a designated service under the AML/CTF Act 2006. Pawnbrokers must enrol with AUSTRAC, implement an AML/CTF Program, conduct customer due diligence, and meet reporting obligations from 1 July 2026. Source: AML/CTF Act 2006, Table 6.
Your obligations
What does AUSTRAC require from jewellers and precious metals dealers by 1 July 2026?
These are the seven steps every in-scope jeweller must complete before obligations commence. Klyvon generates all required documents automatically.
Enrol with AUSTRAC by 29 July 2026
Register at online.austrac.gov.au — you will need your ABN, business details, and the designated services you provide.
AML/CTF Act 2006, s.76
Appoint an AML/CTF Compliance Officer in writing
Designate a named individual — owner or senior employee — responsible for your compliance program, AUSTRAC reporting, and staff training.
AML/CTF Act 2006, s.36
Complete a written ML/TF Risk Assessment
Assess your exposure across client types, transaction values, payment methods, and geographic risk — and document it in your Program.
AML/CTF Rules 2007, Part 8
Implement a written AML/CTF Program (Part A and Part B)
Your Program must cover CDD procedures, transaction monitoring, TTR obligations, SMR procedures, and your record-keeping policy.
AML/CTF Act 2006, s.84
Train all staff on AML/CTF obligations and red flags
Every employee involved in sales or customer interaction must receive AML/CTF awareness training before obligations commence and annually thereafter.
AML/CTF Rules 2007, Part 12
Submit Threshold Transaction Reports for cash sales of $10,000+
Any single cash transaction of $10,000 or more must be reported to AUSTRAC via AUSTRAC Online within 10 business days.
AML/CTF Act 2006, s.43
Submit Suspicious Matter Reports when suspicion arises
If you suspect a customer is engaged in money laundering, terrorist financing, or structuring, submit an SMR within 3 business days — or 24 hours for terrorism financing.
AML/CTF Act 2006, s.41
AUSTRAC guidance
What suspicious activity should jewellers watch for under AUSTRAC guidance?
AUSTRAC published specific red flag indicators for dealers in precious metals, stones, and other products. The following patterns must be escalated to your Compliance Officer and may require a Suspicious Matter Report.
AUSTRAC Risk Insights for Dealers in Precious Metals, Stones and Other Products ↗
Is a customer paying cash at or just below the $10,000 threshold a red flag?
Yes. A customer paying exactly $9,900 in cash — or asking what the reporting threshold is before paying — is a strong indicator of structuring. Under s.142 of the AML/CTF Act 2006, intentionally structuring transactions to avoid the TTR threshold is a criminal offence, and a jeweller who facilitates it may also face liability.
What does it mean when a customer makes multiple linked transactions below $10,000?
A customer making several separate purchases within a short period, each below $10,000 but which together exceed that amount, may be structuring to avoid reporting. Your AML/CTF Program must include procedures to detect and document linked transaction patterns and escalate them to your Compliance Officer.
What if a customer cannot or will not explain where their funds came from?
For high-value purchases — particularly those involving cash — a customer who cannot or will not explain the source of their funds warrants enhanced due diligence and possible SMR lodgement. Source of funds verification is a core requirement of your CDD procedures under ss.32–35 of the AML/CTF Act 2006.
Should I be concerned about an anonymous buyer or an unexplained intermediary?
Yes. A customer attempting to purchase without providing identifying information, or acting through a third party with no clear relationship or authority, is a significant red flag. You cannot complete a designated service without completing required CDD — and an anonymous transaction may itself require an SMR.
What if a customer requests that invoices or payments be split across multiple transactions?
If a customer explicitly requests that a single purchase be split across multiple invoices, payment dates, or payment methods to reduce the apparent transaction value, this is a structuring indicator and must be treated as a suspicious matter requiring documentation and likely SMR lodgement.
What does it mean when a purchase is inconsistent with a customer's apparent financial capacity?
A customer purchasing high-value precious metals or jewellery in circumstances inconsistent with their apparent financial means requires enhanced scrutiny of source of funds and beneficial ownership. This pattern is identified in AUSTRAC's published risk insights as a known money laundering indicator for the sector.
How should jewellers treat customers connected to FATF grey or black list jurisdictions?
Customers whose funds originate from, or who are resident in, countries on the FATF grey or black list carry elevated money laundering risk. Your AML/CTF Program must include a geographic risk assessment, and transactions involving high-risk jurisdictions must trigger enhanced CDD. Source: FATF Country Assessments, incorporated by reference in AUSTRAC guidance.
Is rapid buying and reselling of jewellery or precious metals a money laundering indicator?
Yes. A customer who purchases and quickly resells the same precious metals or high-value jewellery items — particularly at a loss or with no apparent commercial rationale — may be using the transactions to place or layer criminal proceeds. This pattern must be escalated to your Compliance Officer and may require an SMR.
Are virtual asset payments for precious metals a red flag?
Virtual asset payments for high-value precious metals or stones are a known risk indicator under AUSTRAC guidance. The use of cryptocurrency or other virtual assets to purchase precious metals — particularly in high volumes or from unknown parties — warrants enhanced CDD, source of funds verification, and documented risk assessment.
What should jewellers do when a customer seems unusually concerned about avoiding identity verification?
A customer who asks to avoid providing identification, who offers to pay a premium to skip verification, or who becomes evasive when asked standard CDD questions must be treated as a high-risk customer. You cannot proceed with the transaction without completing required CDD — and the behaviour itself may require an SMR. Source: AUSTRAC Risk Insights for Dealers in Precious Metals, Stones and Other Products.
What you get
What does Klyvon's AI generate for your jewellery practice?
Every document is generated for your specific business — your name, your compliance officer, your services. Not a generic template. Every document is generated by AI trained on AUSTRAC's official guidance for your sector — then reviewed and owned by you.
AML/CTF Program Document
Personalised · AI-generatedYour firm-specific compliance program citing the AML/CTF Act 2006 throughout. Covers cash threshold rules, TTR obligations, structuring detection, and jeweller-specific risk factors.
Client Due Diligence Forms
Personalised · AI-generatedCDD procedures for individual and company clients with precious metals-specific enhanced CDD triggers, including source of funds requirements for high-value transactions.
Compliance Officer Letter
Personalised · AI-generatedFormal appointment letter satisfying the written appointment requirement under s.36 AML/CTF Act 2006. Names your designated Compliance Officer and sets out their responsibilities.
AI Suspicious Matter Report Assistant
Personalised · AI-generatedWhen suspicion arises, you have 3 business days to file with AUSTRAC. Klyvon's AI generates a formal 6-section SMR draft from the transaction details you enter — industry-aware language, TTR flag if the amount exceeds $10,000, and your firm's AUSTRAC ID pre-populated. You review and submit.
AI-generated documents are a starting point — reviewed and owned by you. All decisions remain with your firm.
Reporting obligations
What is a Threshold Transaction Report and when must jewellers submit one?
A Threshold Transaction Report (TTR) must be submitted to AUSTRAC for any cash transaction of $10,000 or more — including physical currency and virtual assets. For jewellers this means any single sale or purchase where the customer pays $10,000 or more in cash. The report must be submitted within 10 business days. Source: austrac.gov.au ↗; s.43 AML/CTF Act 2006.
What is structuring and why is it a criminal offence for jewellers?
Structuring is when a customer deliberately splits a transaction into amounts below $10,000 to avoid triggering a Threshold Transaction Report. Under s.142 of the AML/CTF Act 2006, structuring is a criminal offence. Jewellers must be alert to customers making multiple smaller purchases within a short period that together would exceed $10,000.
Source: AML/CTF Act 2006, s.142.
How do I submit a Suspicious Matter Report to AUSTRAC?
Log into AUSTRAC Online at online.austrac.gov.au ↗, select Reporting, then Submit SMR. Complete all mandatory fields including a detailed narrative of the suspicious circumstances. Terrorism financing suspicions must be reported within 24 hours. All other SMRs within 3 business days.
Source: AML/CTF Act 2006, s.41.
What records must jewellers keep and for how long?
All customer identification records, transaction records, TTRs, SMRs, risk assessments, and training records must be retained for a minimum of 7 years from the date the record was made or the transaction completed, whichever is later. Records must be stored securely and be retrievable for AUSTRAC examination.
Source: AML/CTF Act 2006, ss.112, 162; AML/CTF Rules 2007, Part 10.
Enforcement
What are the penalties for jewellers who don’t comply with AUSTRAC?
Under Part 15 of the AML/CTF Act 2006 (Cth), civil penalties for body corporates can reach $33,000,000 per contravention. Criminal penalties apply for operating without enrolment and for serious or wilful non-compliance. AUSTRAC publishes enforcement actions publicly — meaning a penalty carries reputational consequences beyond the financial impact. Professional licences and industry association memberships, including with the Jewellers Association of Australia, may also be affected.
Source: AML/CTF Act 2006 (Cth), Part 15. Penalty figures are indicative — refer to current legislation for precise amounts.
Pricing
How much does it cost to get AML/CTF compliant with Klyvon?
The Australian government estimates the average cost of manual AML/CTF compliance preparation at $23,250 per business when using consultants and lawyers. Klyvon generates your complete compliance documents from $79/month + GST — with all documents ready in under 60 seconds.
Klyvon Compliance Pro — Jewellers & Precious Metals
From $79/month
- ✓ AML/CTF Program Document
- ✓ Client Due Diligence Forms
- ✓ Compliance Officer Letter
- ✓ SMR Template + Filing Guide
- ✓ AUSTRAC Enrolment Guide
Cancel before trial ends — no charge · Documents ready in 60 seconds
Common questions
Common questions from jewellers about AUSTRAC Tranche 2
Does the $10,000 cash rule apply per item or per transaction?
The $10,000 threshold applies per transaction, including linked transactions. A single sale of multiple items totalling $10,000 or more in cash triggers the TTR reporting obligation. AUSTRAC also requires vigilance for linked transactions — multiple purchases structured to stay below the threshold individually may still trigger reporting and SMR obligations.
What if my customer pays partly cash, partly card?
If the total transaction value is $10,000 or more and any portion is paid in cash, a Threshold Transaction Report is required for the cash component. You must report the full cash amount paid, even if only part of the purchase price was settled in physical currency. The card component does not reduce the cash reporting obligation. Source: s.43 AML/CTF Act 2006.
Do jewellers need to verify identity for every sale?
Customer due diligence is required before providing a designated service. For jewellers, this means verifying identity for cash transactions of $10,000 or more, and applying enhanced due diligence for high-risk customers or transactions. Standard retail sales well below the threshold do not individually trigger CDD obligations, but your AML/CTF Program must specify your thresholds and procedures. Source: AML/CTF Act 2006, ss.32–35.
Can a jeweller refuse a sale if a customer won't show ID?
Yes. Under your AML/CTF Program, you must not provide a designated service if you cannot complete the required customer due diligence. If a customer refuses to provide identity documents for a transaction that triggers your CDD obligations, you must decline the transaction and may be required to file a Suspicious Matter Report. Source: AML/CTF Act 2006, s.36.
What is a PEP and why does it matter for a jewellery business?
A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public position — such as a government minister, senior official, or their close associate. Transactions with PEPs carry higher money laundering risk and require enhanced CDD under your AML/CTF Program, including verifying the source of funds for high-value jewellery or precious metal purchases.
Do I need a separate compliance officer or can it be the owner?
The owner or a senior employee can be designated as the AML/CTF Compliance Officer — there is no requirement for a dedicated full-time role. The Compliance Officer must be clearly named in your AML/CTF Program, responsible for staff training, AUSTRAC reporting, and annual program reviews. Source: AML/CTF Act 2006, s.36.
What is beneficial ownership and why does it matter for jewellers?
Beneficial ownership refers to the natural person who ultimately owns or controls a company or trust making a purchase. Jewellers must identify and verify the beneficial owner of any corporate customer that conducts high-value or suspicious transactions. Obscuring beneficial ownership is a known money laundering technique and a red flag under AUSTRAC guidance.
Do jewellers need to verify the identity of wholesale suppliers?
Your CDD obligations primarily apply to customers — parties to whom you provide a designated service. For wholesale suppliers, you should apply appropriate due diligence proportionate to your risk assessment, particularly if dealing in large volumes of precious metals or stones. Your AML/CTF Program should specify your supply chain risk procedures.
What happens if my business misses the 29 July 2026 enrolment deadline?
Operating as a reporting entity without enrolling with AUSTRAC is a contravention of the AML/CTF Act 2006 and may attract civil or criminal penalties. AUSTRAC has indicated it will take a risk-based approach to enforcement, but businesses that fail to enrol by the deadline face significant legal exposure. Enrolment opens at online.austrac.gov.au from 31 March 2026.
Does Klyvon's output satisfy AUSTRAC's AML/CTF program requirements?
Klyvon generates compliance documents built on AUSTRAC's official guidance and citing the AML/CTF Act 2006 and AML/CTF Rules 2007 throughout. The documents are personalised to your business and structured to meet the Part A and Part B program requirements under ss.81–85 of the Act. They are a strong starting point — we recommend review by a qualified AML/CTF adviser before operational reliance.
Can Klyvon help me write a Suspicious Matter Report?
Yes. Klyvon Pro includes an AI Suspicious Matter Report assistant. Enter the transaction date, transaction details, and the suspicious elements you observed. Klyvon's AI generates a formal, AUSTRAC-formatted SMR draft covering all six required sections — reporter obligations under s.41 of the AML/CTF Act 2006, matter details, grounds for suspicion, suspicious indicators, recommended action, and AUSTRAC submission notes. The draft is reviewed by you and submitted directly via AUSTRAC Online. Pro users receive 25 SMR drafts per month.
Ready to generate your AUSTRAC compliance documents?
The 29 July 2026 deadline is 40 days away.