Bullion dealers
Bullion dealers buying or selling gold, silver, and platinum bullion are reporting entities under the AML/CTF Act 2006.
AML/CTF Act 2006 — Bullion Dealers
AML/CTF Obligations
Register with AUSTRAC as a bullion dealer before providing any designated service
Conduct an ML/TF Risk Assessment and implement a unified AML/CTF program
Conduct KYC on customers making cash transactions at or above $10,000 AUD
Lodge TTR reports within 10 business days of a cash transaction at or above $10,000 AUD
Lodge SMR reports within 3 business days of forming a suspicion
Maintain all CDD and transaction records
Bullion dealers must lodge TTR reports within 10 business days of a cash transaction at or above $10,000 AUD. SMR reports must be lodged within 3 business days of forming a suspicion.
Typical Customer Risk Profiles
Cash buyers near or just below the $10,000 threshold — a customer who regularly buys $9,500 in bullion is displaying classic structuring. The pattern matters, not just the individual transaction.
First-time buyers making large cash purchases — a customer with no prior relationship arriving with a large amount of cash is a high-risk profile that requires documented source of funds.
Buyers from high-risk jurisdictions — foreign nationals purchasing significant quantities of bullion, particularly in cash, without an Australian financial footprint require EDD.
Sellers with unverifiable provenance — customers wanting to sell bullion who cannot document its legitimate origin may be disposing of proceeds of theft or other criminal activity.
Recommended Compliance Pack
Bullion Pack
Pre-configured for Bullion dealers — KYC rules, risk thresholds, AUSTRAC report templates, CDD workflows, and monitoring rules aligned to your obligations. Ready from day one.
View pack detailsWhat's included
System default — customisableCustomer onboarding and KYC workflows calibrated for bullion transaction thresholds
TTR report templates pre-populated from transaction records with AUSTRAC validation
Structuring detection alerts for customers making multiple transactions below TTR thresholds
PEP and sanctions screening at point-of-sale customer identification
AML/CTF program template for bullion dealers with transaction risk assessment and training log
Example workflow
Default — you can modify stepsCustomer approaches for purchase
Sale at or above $10,000 in cash? KYC triggered at point of sale. Digital ID check sent to customer.
Identity verified
Photo ID captured and verified. Sanctions screening runs automatically.
Source of funds documented
Customer provides documentation of where the cash originated. Stored securely.
TTR generated
Cash transaction at or above $10,000? TTR auto-populated from transaction data and queued for review.
Structuring check
Customer's transaction history reviewed. Pattern of purchases just below $10,000? Alert raised for MLRO.
TTR submitted or SMR filed
TTR submitted to AUSTRAC within 10 days. Suspicious pattern? SMR prepared and filed within 3 days.
Pricing Recommendation
Recommended
Essential
Bullion dealers primarily need TTR generation, KYC at point of sale, and structuring detection. The Essential plan covers these core obligations.
View full pricingReady to get compliant as a Bullion?
Your Bullion Pack is configured on day one. 7-day free trial — no credit card, no consultants, no configuration sprints.