Tranche 1 · Bullion dealers
AML compliance for bullion dealers
Buying and selling bullion is a designated service. High-value physical transactions demand reliable identity verification, screening and record-keeping that do not obstruct legitimate trade.
Need specialist support? Speak with our in-house team.
Am I captured?
Buying and selling bullion is a designated service.
Designated services include:
- Buying bullion
- Selling bullion
Jewellers and coin dealers may also be captured here or under precious metals and stones, depending on what they actually sell.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. Treat a bullion sale like any other high-value designated service: identify the customer, screen them, and keep the invoice and ID with the lot. Threshold and cash rules still apply.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your bullion business could be used for money laundering or terrorism financing — customers, products, transaction channels and geography — and keep that assessment current as your operations change.
AML/CTF program
Put in writing how your bullion business will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
This is a plain-English guide, not a determination of your status. If unsure, use the Am I in scope? guide or speak with us.
How Trancher helps
Identity verification, screening and record-keeping around high-value bullion transactions, with the invoice, ID and supporting evidence kept together for audit.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your business — use Trancher within your existing AML/CTF operations, add expert support where needed, or have agreed activities managed for you.
Path 1
Self-managed
Use Trancher within your existing AML/CTF program, with clear workflows and built-in guidance.
From $9.99 per week.
Path 2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with implementation, risk assessment, program updates, onboarding, training or operational reviews.
Path 3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your business’s behalf.
Need specialist support? Speak with our in-house team.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
Guides and articles for bullion dealers
Questions from bullion dealers
Am I captured?
Buying and selling bullion is a designated service. Jewellers and coin dealers may also be captured here or under precious metals and stones, depending on what they actually sell.
What are the deadlines?
[Answer needed — deadlines and enrolment timing for Tranche 1 entities]
What goes in the program?
[Answer needed — program content for a bullion dealer]
What does CDD look like in practice?
[Answer needed — CDD in practice for bullion dealers]
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.