Paper 3 — information for dealers in precious metals and precious stones who are proposed to be brought under the AML/CTF regime.

AML Guru
2 min readMay 7, 2024

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This is an article of a series of articles explaining proposed measures to amend AML/CTF regime by the Attorney General’s Dept.

The paper outlines the implementation details for businesses dealing in precious metals and precious stones. These steps include enrolling with AUSTRAC, developing a tailored AML/CTF program, conducting customer due diligence (both initially and on an ongoing basis), reporting suspicious activity, and maintaining accurate records.

What Activities are Captured?

It’s important to understand that the reforms focus on a specific activity: accepting or paying cash (physical currency) or digital assets of $10,000 or more for the sale or purchase of precious metals, precious stones, or jewelry containing these materials. This applies to transactions conducted in the course of business.

If a business exclusively utilizes alternative payment methods for transactions exceeding $10,000 (such as electronic funds transfer, checks, or credit cards), such businesses wouldn’t be subject to the AML/CTF requirements under this proposal. In this scenario, such business wouldn’t be considered a reporting entity.

Business Responsibilities

  1. Enroll with AUSTRAC.
  2. Develop and maintain a comprehensive AML/CTF program specific to your company’s needs.
  3. Conduct thorough initial customer due diligence.
  4. Implement procedures for ongoing customer due diligence.
  5. Report certain transactions and any suspicious activity identified.
  6. Establish and maintain accurate records.

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