Dealing in bullion, and where AML/CTF touches it
Bullion dealing is one of two services in Table 2. It has its own threshold, its own list of metals, and it works differently from the jewellery item sitting next to it.
Start here
What bullion is
Bullion is precious metal held for its metal value rather than its craftsmanship: bars and bullion coins, bought and sold close to the spot price.
The Act names four metals — gold, silver, platinum and palladium — in the relevant forms. That list is the first thing to check, because it is narrower than people assume.
And it is a genuinely different service from selling jewellery. A gold ring is not bullion. It is a precious product, which is item 2 — a different item with a different threshold that works in a completely different way.
What counts, and what does not
| What it covers | |
|---|---|
| Gold | Bars, cast bars, minted bars and bullion coins |
| Silver | Same forms — the metal is what matters, not the mint |
| Platinum | Less common at retail, equally within the item |
| Palladium | Included by the Act’s definition |
| Not bullion | A gold ring, a watch, a necklace — those are precious products under item 2 |
The size of it
A single mint sold 23,932 ounces of gold in one month
That is the Perth Mint’s minted product sales for August 2026, alongside 333,880 ounces of silver. It is one seller among many, and it gives a sense of the volume moving through the Australian market.
Section 39E exempts item 1 where the retail value of the bullion is less than $5,000
Gold, silver, platinum and palladium, in the relevant forms
Gold sold in minted product form in a single month
Bullion dealing became a designated service under Table 2, item 1
How the threshold works
$5,000 of metal, however the customer pays
Section 39E exempts item 1 where the retail value of the bullion is less than $5,000. Above that, the service is caught.
Note what the threshold attaches to: the value of the metal. Not the payment method. A $20,000 gold purchase paid entirely by bank transfer is still a designated service.
That is the opposite of how the jewellery item works, and it is the single most common confusion between the two. Item 2 asks how the customer paid. Item 1 asks what the metal was worth.
| The purchase | Retail value | Position |
|---|---|---|
| A customer buys a 1 oz gold bar | Well above $5,000 at current prices | Caught |
| A customer buys a 1 oz silver coin | A long way under $5,000 | Exempt under s 39E |
| A customer buys $6,000 of silver coins in one purchase | Retail value above $5,000 | Caught |
| A customer pays by bank transfer rather than cash | Makes no difference to item 1 | Still caught if the value is above $5,000 |
What actually gets checked
Six checks, at the counter
The last one is particular to threshold-based services. Where a line exists, someone will sit just underneath it — and a pattern of purchases each a little below $5,000 is exactly what the monitoring obligation is for.
| The check | What is required | How it is usually done | What stays in the file |
|---|---|---|---|
| Identify the customer | Full name, date of birth and residential address of the buyer or seller | Licence or passport, at the counter or by digital check | What was collected and how it was verified |
| Look through entities | If the customer is a company or trust, who owns or controls it | ASIC extract, trust deed | Who they are and the document relied on |
| Screen for PEPs and sanctions | Whether the customer is politically exposed, and a check against the DFAT Consolidated List | A screening tool, or a manual DFAT search | The result and its date |
| Understand the purpose | What the purchase or sale is for | Investment is the ordinary answer | A note where the pattern is unusual |
| Rate the risk | Assess and record the ML/TF risk of the customer | Your program’s risk factors — repeat purchases just under a threshold matter | The rating and the reasons |
| Watch for structuring | Monitor for transactions split to stay under a line | Several purchases in a week, each just under $5,000 | What you noticed, when, and what you did |
Records are kept for 7 years. Deliberately structuring transactions to fall under a threshold is itself an offence.
The provision itself
Table 2, item 1, in the Act’s own words
“buying or selling bullion, where the buying or selling is in the course of carrying on a bullion‑dealing business”
Customer: the buyer or the seller (as the case may be). Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(3) table 2, item 1 — Compilation No. 62 (C2026C00274). The $5,000 exemption is in s 39E, not in the item itself.
Two phrases carry it. “Bullion” is defined in the Act and limits the metals. “In the course of carrying on a bullion-dealing business” means this is about dealers, not about a private individual selling their own coins.
The thirteen designated services
One article for each service you can select when you enrol
13 of 13 written so far. The rest are in progress.
- ConveyancingEvery step of a settlement, and how CDD differs from the VOI you already do.Table 6, item 1
- Selling a businessWhen a company or trust changes hands.Table 6, item 2
- Client moneyHolding or controlling someone else’s money or property in a transaction.Table 6, item 3
- Equity and debt financingRaising money for a company or legal arrangement.Table 6, item 4
- Shelf companiesSelling or transferring a company created to be sold.Table 6, item 5
- Company and trust formationCreating or restructuring a company, trust or partnership.Table 6, item 6
- Director and trustee rolesActing as, or finding someone to act as, a director, trustee or attorney.Table 6, item 7
- Nominee shareholdersHolding shares in your name for somebody else.Table 6, item 8
- Registered officeLetting a client use your address as their registered office.Table 6, item 9
- Real estate agentsThe agent’s customer is both sides of the deal — and the two sides start at different moments.Table 5, item 1
- Property developersSelling your own stock with no agent in between, and why that changes who the customer is.Table 5, item 2
- Bullionyou are hereGold, silver, platinum and palladium, and the $5,000 exemption.Table 2, item 1
- Jewellers and dealersWhy the $10,000 line is about how the customer pays, not what they buy.Table 2, item 2
Sources
Where every figure here comes from
Data as at 27 September 2026.
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006, s 6(3) table 2 and s 39E · Federal Register of Legislation · Compilation No. 62 (C2026C00274)Item 1, quoted verbatim on this page, and the $5,000 retail-value exemption in s 39E.
- Bullion dealers · AUSTRAC · Guidance, current at Sep 2026AUSTRAC’s own guidance for the sector.
- Monthly sales figures · The Perth Mint · August 202623,932 oz of gold, 333,880 oz of silver and 1,060 oz of platinum sold in minted product form in August 2026.
- Gold market structure and size · The Perth Mint · CurrentHow the bullion market is structured.
Before you rely on this
This content is general information only. It is not legal, financial or compliance advice. Organisations should check AUSTRAC guidance, legislation, their own AML/CTF Program and professional advice where needed.
- The $5,000 figure comes from s 39E. Check the current provision before relying on it — exemptions can be amended.
- Whether a product is bullion or a precious product depends on the item and the Act’s definitions, not on how it is marketed.
- Current as at 27 September 2026.
Lex-AML supports compliance workflows and record keeping. It does not provide legal advice, does not guarantee compliance, and does not replace professional judgement or advice from a qualified AML/CTF adviser or legal professional.
GetPost Labs is a technology company. We are not a law firm and not a compliance adviser, and this page is not a substitute for either.
We build Lex-AML. To build it properly we had to understand these obligations the way the people carrying them do, so we researched them with small and medium practices across the affected sectors — how the work actually runs, where the law lands inside it, and which questions were hardest to get a straight answer to. Publishing what we found is how we check that we have understood a requirement before we build for it.
That understanding is also what we bring to a conversation. No two practices run a matter the same way, and tooling that assumes one way of working fits almost nobody. We would rather start from how you already work — your intake, your file, your sign-off, the software you already pay for — and shape the compliance work around that than hand you a process and ask you to adopt it.
So this is an offer of capability, not a pitch. If Lex-AML turns out to fit your practice, we would like to work on it with you. If it does not, what is written on this page stands on its own, and every source it rests on is listed above so you can check it yourself.