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Bullion & Jewellers AML/CTF Compliance

AML/CTF Compliance for Bullion & Jewellery Businesses

The bullion and jewellery sector is firmly on the regulatory radar. Existing bullion dealers already have obligations under the AML/CTF Act and Rules, and upcoming reforms will extend those obligations to a wider range of businesses dealing in precious metals, stones and related products. That means more businesses must enrol with AUSTRAC, implement risk-based AML/CTF programs, carry out customer due diligence, monitor transactions and submit reports – all while keeping day-to-day operations running smoothly.

Plan for Wealth helps bullion dealers, jewellery retailers, refiners and precious-metal traders build robust, practical AML/CTF frameworks that align with AUSTRAC’s requirements and anticipated reforms. We design and review AML/CTF programs, write SOPs, streamline processes, and support you with reporting, onboarding and deal execution so you can operate confidently and compliantly.

Important: We provide AML/CTF consulting, documentation and process design. We do not provide legal advice or financial product advice. Where legal or licensed financial advice is required, we work alongside appropriately qualified professionals.

AML/CTF Program Design & Reform Readiness

As regulation expands to cover more precious metal and jewellery businesses, generic off-the-shelf policies are no longer enough. Regulators expect risk-based programs that reflect the real risks and realities of your business.

We help you stay ahead of these changes by:

  • Designing tailored AML/CTF programs for bullion and jewellery operations (retail, wholesale, online, refinery, pawnbroking and more).
  • Conducting business-wide AML/CTF risk assessments and aligning your controls with those risks.
  • Incorporating current AUSTRAC expectations and reform directions into your program from the outset.
  • Building in clear responsibilities for owners, compliance officers and frontline staff.

The result is a documented, defensible program that you can explain to AUSTRAC, your bank and your counterparties – and that your team can actually use.

SOPs, Workflows & Process Improvement

A policy on paper is not enough; your team needs clear, step-by-step instructions.

We write and refine SOPs and workflows for:

  • Customer onboarding and KYC – identification, beneficial ownership, risk-rating and ongoing due diligence.
  • Transaction monitoring – what to look for, when to escalate, and how to record decisions.
  • Enhanced due diligence and suspicious activity management – triggers, escalation paths and documentation.
  • Threshold transactions, record-keeping and internal reporting.
  • Clarifying roles, responsibilities and internal controls so everyone knows who does what, and how.

We also review your existing operational processes – in-store, online and back office – to:

  • Remove duplication and manual rework.
  • Close gaps where risky transactions or customers could bypass controls.
  • Make AML/CTF a natural part of your sales and trading process rather than an afterthought.

The outcome is simpler, repeatable processes that support both compliance and commercial flow.

3. AUSTRAC Enrolment, Reporting & Ongoing Compliance

For many jewellers and precious-metal businesses, AUSTRAC is new territory. We help you navigate it without the overwhelm.

Our support includes:

  • Assisting with AUSTRAC enrolment and registration as a reporting entity.
  • Designing your internal process for Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs) and other required reports.
  • Creating templates and checklists for documenting suspicions, decisions and follow-up.
  • Helping you prepare for AUSTRAC compliance reporting and periodic internal reviews of your AML/CTF framework.

We focus on building repeatable routines so reporting becomes a disciplined habit rather than a scramble.

4. Onboarding Support & Access to International Brands

High-value precious metals and jewellery are attractive to criminals because they are portable, liquid and easily traded. This makes customer onboarding and KYC critical – not only for AUSTRAC compliance but also for maintaining banking relationships and wholesale supply lines.

We help you:

  • Design onboarding and KYC processes that satisfy AUSTRAC expectations and the risk standards of major refiners, mints and wholesalers.
  • Put in place documentation and controls that make you a low-risk, well-prepared counterparty for international brands and distributors.
  • Build internal tools (forms, checklists, digital workflows) that make onboarding consistent and auditable.

In short, we help you become the kind of business that counterparties and financial institutions are comfortable dealing with.

Buyers Agent & Deal Negotiation for Bullion

Compliance is one side of the equation; sourcing and pricing physical metal effectively is the other.

We act as a buyers-side representative for:

  • High-net-worth individuals and family offices.
  • Jewellery and bullion businesses seeking wholesale product.
  • Corporate and professional buyers who need reliable, documented sourcing.

Our role includes:

  • Comparing different forms and brands of bullion (e.g. bars, coins, products from established refiners and mints).
  • Negotiating pricing and trading terms with appropriate counterparties on your behalf.
  • Coordinating product selection and readiness – including bar sizes, coin programs and preferred formats.

You remain in control of decisions while we source options, handle discussions and document the process to support both commercial and compliance needs.

Support for SMSF & Precious-Metal Investors

Many investors and SMSF trustees use physical precious metals as part of a broader diversification strategy. These arrangements must be approached carefully, with attention to structure, storage and documentation.

For SMSF trustees and other precious-metal investors, we provide:

  • Factual information on different types of bullion products, storage approaches and liquidity considerations.
  • Practical guidance on how transactions with dealers and custodians typically work, so you can ask the right questions and set clear expectations.
  • Assistance in coordinating purchases or sales with bullion providers and storage solutions, acting as your representative where appropriate.

We do not provide financial product advice or recommend specific investment strategies. Our role is to inform, organise and execute once you and your licensed advisers are comfortable with the direction.

Why Work With Plan for Wealth on Bullion & Jewellery Compliance?

  • Sector-specific focus – we understand the realities of bullion and jewellery trading, not just generic AML theory.
  • End-to-end coverage – from risk assessments, policies and SOPs to reporting workflows, onboarding designs and deal support.
  • Commercial and compliance balance – we help you protect your licence and reputation while still trading efficiently and serving customers.
  • Global perspective – our experience with international brands and cross-border transactions helps you position your business as a serious, well-run counterparty.

You get a partner who can talk regulation, operations and bullion markets in the same conversation, and who is focused on practical, sustainable solutions.

For employers:

Need to get your bullion or jewellery business compliant and commercially ready for the next wave of AML/CTF regulation?

Book a Bullion & Jewellers AML/CTF Consultation with Plan for Wealth to:

  • Assess your current AML/CTF position and gaps.
  • Design or uplift your AML/CTF program, SOPs and reporting processes.
  • Explore buyers-agent support, deal negotiation and SMSF-friendly bullion sourcing.

Contact us today to schedule a confidential discussion and put a clear, compliant and commercially sensible framework in place.

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