Sectors · Dealers

AML/CTF for jewellers and bullion dealers: two different Table 2 services

Jewellery and other precious goods are covered by Table 2 item 2 when the relevant physical-currency or virtual-asset threshold is met. Bullion dealing is a separate Table 2 item 1 service with different CDD rules.

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Quick answer

Cash and crypto decide it, not the price tag

A high-value item is not enough by itself. For the precious-goods service, look at how the customer pays and whether linked transactions count together for the designated-service threshold.

Whether your business is a reporting entity depends on the designated services you provide — not on having an ABN or being based in Australia. Check AUSTRAC’s sector guidance, and seek professional advice for your situation.

The full guide

AML for jewellers: the $10,000 line is about how they pay

Why a $60,000 card sale is not caught and a $10,000 cash one is, how linked sales add up, and what to do at the till.

Read it

Sales, sorted

Which dealing is caught

The “Where” column shows whether each row is a designated service, an exclusion in the Act or an example from AUSTRAC’s guidance. Caught rows link to the article that covers them in full.

Which dealing is caught
The work	Caught?	Where
Selling jewellery, a watch or loose stones where $10,000 or more is paid in cash or virtual assets	Caught	Table 2, item 2
Buying gold or gems from a member of the public, paying $10,000 or more in cash	Caught	Table 2, item 2
Several linked purchases that together reach $10,000 in cash	Caught	Table 2, item 2 — linked transactions
A $60,000 ring paid for entirely by card	Not caught	No physical currency or virtual assets
Buying or selling bullion in a bullion-dealing business	Caught	Table 2, item 1
Bullion with a retail value under $5,000	Caught	Designated service · initial CDD may be exempt — Table 2 item 1, s 39E

Bullion has its own guide: AML for bullion dealers: the designated service and $5,000 CDD exemption.

The legislation

Table 2, in the Act’s own words

Dealers sit in Table 2 of section 6(3) — not with the professions in Table 6. The two items, unparaphrased:

The Act — s 6(3) table 2, item 1
“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.

The Act — s 6(3) table 2, item 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 physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products; (d) any combination of any 2 or more of the items referred to in paragraphs (a) to (c)”
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.

The $10,000 threshold bites on physical currency or virtual assets, not on the sale price — a $60,000 ring paid for by card is not item 2; the same ring paid for with $10,000 cash and the rest by card is. “Precious product” is defined widely in s 5A and reaches jewellery, watches and objects of personal adornment.

At the counter

Two questions to settle before the sale

How much is physical currency or virtual assets?

The threshold applies to those payment types, not simply the item’s price.

Are the transactions linked?

Linked purchases can count together for the designated-service threshold. A customer splitting a cash purchase across visits does not take it out of item 2. The jewellers guide covers how to handle it at the till.

See it in Lex-AML

Watch the full user journey

Lex-Brisbane Jewellers, a fictional Brisbane business, sells an engagement ring to Michael Thompson, who pays in cash. Daniel Rossi, the business’s AML/CTF compliance officer, runs the matter in the Lex-AML Organisation Workspace; Michael only uses the Customer Portal.

Video thumbnail: Lex-AML for Jewellers — Complete End-to-End Walkthrough

Or watch it in six short parts

The whole series on YouTube

One example of how a matter in a jewellery business can run in Lex-AML, which is configured around each organisation’s own AML/CTF program. The business and its customers are fictional, the identity and screening checks use demo providers, and no real customer information is shown. The organisation makes every customer due diligence decision. Not legal advice.

What follows

What a dealer has to do

In the order the Act sets them, once the business provides a designated service.

Before the first designated service — have the required ML/TF risk assessment and AML/CTF policies in place, and complete initial customer due diligence unless an exemption or permitted delayed-CDD rule applies. CDD explained
Within 28 days after starting — if not already enrolled, apply to enrol with AUSTRAC, and designate the AML/CTF compliance officer if one is not already designated.
Ongoing — apply ongoing customer due diligence, make required reports and keep the required records.

See how the AML/CTF program fits together →

If this is work you do

Which of these services does your firm provide?

Lex-AML starts by recording the designated services your firm actually provides, then helps you organise your AML/CTF program, customer due diligence and audit trail around them.

Request demo access Or ask for a quote for your firm

Watch

Jewellers and dealers: what the law actually asks

How the relevant cash or virtual-asset threshold can make a precious-goods sale a designated service.

Video thumbnail: Jewellers & dealers — the $10,000 cash line (s 6, table 2)

Read the transcript, with the law quoted

Questions

AML/CTF for jewellers and dealers: common questions

Are jewellers covered by the AML/CTF Act?

From 1 July 2026, yes — when they buy or sell precious metal, precious stones or precious products and the purchase involves $10,000 or more in physical currency or virtual assets. That is item 2 of Table 2 in section 6(3).

Does a $10,000 card payment count?

No. The threshold is about physical currency and virtual assets. A sale paid entirely by card is not item 2, whatever the price.

What if a customer splits the cash over several visits?

Item 2 counts purchases made in several transactions that are linked or appear to be linked, so splitting a cash purchase does not take it outside the threshold.

Are bullion dealers covered?

Yes. Buying or selling bullion in the course of a bullion-dealing business is item 1 of Table 2. Where the retail value is under $5,000, section 39E can exempt the reporting entity from initial CDD for that customer, subject to the conditions in that section. The service itself remains a designated service.

What does a dealer have to do first?

Before first providing a designated service, have the required ML/TF risk assessment and AML/CTF policies in place and complete initial customer due diligence unless a lawful exception applies. If the business is not already enrolled, it must apply to enrol with AUSTRAC within 28 days after it starts providing the service, and designate an AML/CTF compliance officer within the same period if it has not already. Ongoing customer due diligence, suspicious matter and threshold transaction reporting and record keeping continue after that.