AML/CTF compliance for Australian jewellers and precious-metals dealers — what AUSTRAC and the OAIC expect

A primary-source briefing for jewellery retailers, bullion dealers and precious-stone traders who become reporting entities once a transaction crosses the AUD $10,000 cash or virtual-asset threshold. Quotes are verbatim from AUSTRAC's January 2026 sector starter kit and the OAIC's CC BY 4.0 templates.

Published 14 May 2026 · privacycovered.com.au

What AUSTRAC says about jewellers and precious metals

"Australia's 2024 money laundering national risk assessment assesses luxury goods (including jewellery and watches) as having a very high and stable vulnerability to money laundering. It's expected that luxury goods will continue to pose a very high vulnerability to money laundering."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Money laundering: Inherent risk".

"The buying, selling and movement of precious metals, stones and products provide an effective and low-cost channel for criminals to launder funds. In Australia, high-value watches and jewellery are commonly identified by authorities in money laundering investigations."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Money laundering: Inherent risk".

"Precious metals, stones and products are attractive for money laundering because: they require minimal to no knowledge, skills or expertise to acquire, store and maintain; they're easily moved into and out of both licit—including second hand—and illicit markets; the global second-hand market for many forms of luxury goods is expansive, featuring many private sellers and traders, including those based offshore; they often retain very high value, and in some cases, appreciate in value; in many cases, they're easily transported."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Money laundering: Inherent risk".

Your designated service (Item 2 of Table 2)

"Buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of both) with a total value of $10,000 or more, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: 1. precious metal 2. precious stones 3. precious products 4. any combination of any 2 or more of the items referred to in paragraphs a) to c). (Item 2 of Table 2 of the AML/CTF Act)"

"Examples of precious products include a: ring crafted from gold and pearl; stainless-steel watch with diamonds set on the face; headdress made of platinum and garnet; gold or diamond grill (dental jewellery)."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Designated services: Inherent risk".

The threshold is total value, not unit price: linked transactions count cumulatively.

Risk indicators AUSTRAC names

"A precious metal, stone or product will be high risk where they satisfy all the following: effectively retain or increase in value over time; are easy to transport, on-sell and hide in bulk; don't need significant labour to improve before on-selling. This includes, but isn't limited to: gold (18 carat or more); platinum; single/loose diamonds (50 points and above)."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Designated services: Risk factors — High-risk metals and stones".

"Precious metals, stones, and product transactions have the potential to involve large sums of money, making them attractive for laundering significant amounts of illicit funds. This risk is magnified when purchases or sales are made using physical currency. This is because these payments bypass financial institutions and are more difficult to track and identify who is making them."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Designated services: Risk factors — High value physical currency transaction".

"The use of 'money mules' to purchase precious metals, stones and products for ML/TF networks remains a common money laundering method… Attention should be given where delivery is made to an address that isn't the customers, or where individuals are observed to be interacting with another person in the immediate vicinity of the premises."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Common ML/TF methods — Transactions involving third parties or 'money mules'".

"Where customers conduct transactions that are below known reporting thresholds (including the $10,000 threshold required to trigger regulation) to avoid triggering AML/CTF reporting obligations. Customers conducting multiple transactions below reporting thresholds may be trying to evade AML/CTF reporting requirements."

— AUSTRAC, Jewellers — Risk assessment — January 2026, "Common ML/TF methods — Structuring".

The Privacy Act overlay — what the OAIC expects

Once you are a reporting entity, the personal information you collect to verify customer identity is governed by the Privacy Act 1988 regardless of your business turnover. The OAIC publishes the framework:

"The Office of the Australian Information Commissioner's (OAIC) Privacy management framework outlines steps to take to meet your ongoing compliance obligations under Australian Privacy Principle (APP) 1.2. A key tool to help you meet these requirements is to develop and implement a privacy management plan."

— OAIC, Privacy management plan template, distributed under CC BY 4.0.

"We collect your personal information to comply with the 'Customer Due Diligence' requirements in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). This includes to: establish and verify your identity before providing certain services to you or the person you are acting on behalf of; assess and manage potential money laundering, terrorism financing, proliferation financing risks or related compliance risks associated with the provision of our services; make reports required by law under the AML/CTF Act; meet record keeping obligations under the AML/CTF Act."

— OAIC, Template privacy collection notice for reporting entities under the AML/CTF Act, distributed under CC BY 4.0.

What this means in practice

For a jewellery or bullion business, the 1 July 2026 minimum surface is:

• Enrolment with AUSTRAC and an appointed AML/CTF Compliance Officer.
• A Customer Due Diligence process that triggers at the $10,000 threshold — and that detects linked transactions sitting just below it.
• PEP and sanctions screening for triggered customers.
• A 7-year record retention scheme (s.107 transactions, s.113 CDD, s.116 program).
• A documented AML/CTF program approved by the governing body under s.26F.
• An OAIC-compliant privacy program: APP 1.3 policy, APP 5 collection notice issued at the CDD step, APP 11 security for stored ID documents, and a Notifiable Data Breach response procedure under Part IIIC.

For the full statutory framework and a 6-week countdown plan, see the Tranche 2 explainer.

This page reproduces verbatim passages from AUSTRAC's January 2026 sector starter kits (used under AUSTRAC's published licence) and the OAIC's Privacy Management Plan template and AML/CTF Privacy Collection Notice template (used under CC BY 4.0). It is not legal advice. The OAIC and AUSTRAC have not endorsed privacycovered.com.au or any product or service offered through it. Engage qualified Australian counsel to confirm the obligations and documents fit your business's circumstances.