Do precious metals and stones dealers need to maintain a written AML/CTF program?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Yes
Yes. This obligation applies to precious metals and stones dealers whatever their structure or size. The deciding fact: Dealer in precious metals or stones — a reporting entity from 1 July 2026 if any sale or purchase is $10,000+ in cash or virtual assets (answer the designated-services question to confirm).
The obligation in brief
Maintain a written AML/CTF program. Under the reformed AML/CTF Act (in force for existing reporting entities from 31 March 2026 and for Tranche 2 entities from 1 July 2026), a reporting entity's AML/CTF program is an ML/TF risk assessment plus AML/CTF policies that mitigate and manage those risks — this replaced the former Part A / Part B structure. The policies cover customer due diligence, ongoing CDD, transaction monitoring, reporting, record keeping, personnel due diligence and training, governance and senior manager approval, and the designation of an AML/CTF compliance officer.
Trigger: Becoming a reporting entity.
Why precious metals & stones dealers get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 27 of those industries the answer for "Maintain a written AML/CTF program" is no. Precious metals & stones dealers is one of the 8 where the answer is different: yes.
The deciding fact for precious metals and stones dealers: Dealer in precious metals or stones — a reporting entity from 1 July 2026 if any sale or purchase is $10,000+ in cash or virtual assets (answer the designated-services question to confirm)
About the industry: Dealers in gold, silver, platinum, and precious stones for transactions involving $10,000+ in physical currency.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires an AML/CTF designated service).
Answer by business structure and size
Each cell is the engine's outcome for a business in precious metals & stones dealers with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Yes | Yes | Yes | Yes | Yes | Yes |
| Partnership | Yes | Yes | Yes | Yes | Yes | Yes |
| Trust | Yes | Yes | Yes | Yes | Yes | Yes |
| Pty Ltd company | Yes | Yes | Yes | Yes | Yes | Yes |
| Public company | Yes | Yes | Yes | Yes | Yes | Yes |
| Not-for-profit (unregistered) | Yes | Yes | Yes | Yes | Yes | Yes |
| Registered charity | Yes | Yes | Yes | Yes | Yes | Yes |
| Super fund | Yes | Yes | Yes | Yes | Yes | Yes |
| Foreign company | Yes | Yes | Yes | Yes | Yes | Yes |
Designated services that catch precious metals & stones dealers
| AML/CTF Act reference | Service | Customer for due diligence |
|---|---|---|
| s 6 table 2 item 2, s 5A | Buying or selling precious metals, stones or products for the cash threshold or more in physical currency and/or virtual assets, single or linked | The buyer or seller |
- Card, bank transfer and other non-cash payments do not count towards the threshold.
- Precious-metal products are those with at least 2% precious metal by weight (s 5A(1)(j)).
AUSTRAC publishes a jeweller starter kit for dealers that accept no virtual assets and take regulated cash only from individual customers, and that meet the other suitability criteria.
What the obligation requires
- When due
- Before providing the first designated service. Maintained on an ongoing basis, with independent evaluation at least once every 3 years.
- Evidence to keep
- ML/TF risk assessment, AML/CTF policies, governing body / senior manager approval records, compliance officer designation and AUSTRAC notification, training records, independent evaluation report.
- Maximum penalty
- Civil penalty of up to $36.4M (body corporate) or $7.28M (individual), maximum per contravention. Separate criminal offences also apply.
- Regulator
- AUSTRAC
- Jurisdiction
- Commonwealth (national)
Other obligations where precious metals & stones dealers differ from the norm
- Customer due diligence (KYC) on every customer: Yes
- Designate an AML/CTF Compliance Officer: Yes
- Detect + enhance due diligence on Domestic + Foreign PEPs: Yes
- Enrol with AUSTRAC as a reporting entity: Yes
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC: Yes
- Independent review of AML/CTF program: Yes
- All 17 answers for precious metals & stones dealers
Other industries with a non-default answer
Questions
- Do precious metals and stones dealers need to maintain a written AML/CTF program?
- Yes. This obligation applies to precious metals and stones dealers whatever their structure or size. The deciding fact: Dealer in precious metals or stones — a reporting entity from 1 July 2026 if any sale or purchase is $10,000+ in cash or virtual assets (answer the designated-services question to confirm).
- Is the answer the same for every industry?
- No. For 27 of the 35 industries Rules Mate maps, the answer is no. Precious metals & stones dealers is one of 8 industries with a different answer.
Related
Sources
- AUSTRAC: official source
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006
- AUSTRAC guidance
- AUSTRAC: Precious metals, stones and products designated services
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (compilation in force 1 Jul 2026)
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.