There are roughly 1,400 dealers in precious metals and stones across Australia who fall within the Tranche 2 definition. Most are small, owner-operated and have never run any kind of compliance program. They are also the highest per-transaction risk category in the new cohort because cash, anonymity and portability all converge.
The trigger transactions
- Any transaction at or above A$10,000 in cash or equivalent — TTR mandatory.
- Aggregated transactions from the same customer that breach A$10,000 within a defined window — structuring concern.
- Sales of investment-grade bullion regardless of value where the customer is non-resident.
- Buy-back arrangements (taking gold or stones in for resale) — both sides require CDD.
What good looks like
A point-of-sale workflow that triggers ID capture and screening before the customer leaves the counter, an audit log that survives staff turnover, and a quarterly review of high-value customers against updated sanctions lists. Most of this is achievable with TrustSoft or WatchEye for under A$250/month — the operational change is harder than the software.