CLICK ITEM TO JUMP TO RELEVANT SECTION
» Background: The roots of reform
» Who does this impact?
» The Jeweller's Fork in the Road: To opt in, or not to opt in?
» Hard v Soft Opt-Out: What's the difference?
» Attention all Jewellers: Minimum requirements for every business
» Final thoughts: Proceed with caution
KEY TERMS & DEFINITIONS • Virtual Assets
A digital representation of value that can be transferred, stored, or traded electronically. This category encompasses digital currencies, such as cryptocurrencies, and is subject to AML/CTF oversight to mitigate risks like illicit fund transfers. • Linked Transactions
Transactions that are regarded by AUSTRAC as interconnected or related. Examples include the deliberate splitting of a larger transaction into smaller ones below the $10,000 threshold to evade AML/CTF obligations, or multiple payments that are connected by shared elements such as invoices, payment methods, or dates of sale¹. Identifying linked transactions is crucial for detecting patterns of suspicious activity. • Structured Transactions
The intentional division of a larger transaction into smaller, discrete transactions to circumvent AML/CTF reporting requirements, particularly thresholds like the $10,000 cash transaction limit¹. This practice is a common money laundering technique and triggers enhanced scrutiny under regulatory guidelines. • Soft Opt-Out
A business that has chosen to opt out of being a reporting entity but adopts a formally documented cash-acceptance policy that limits cash receipts per customer and includes monitoring controls to prevent aggregation of linked transactions that would otherwise trigger obligations under the AML/CTF framework. Still required to commit to minimum requirements. • Hard Opt-Out
A business that elects not to be a reporting entity under the AML/CTF Act and therefore refuses to engage in designated services involving cash or other specified forms of value that would trigger reporting obligations. Still required to commit to minimum requirements. |
On 1 July 2026, the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms will expand their reach into the jewellery industry, requiring vigilance and strategic decision-making.
These reforms expand upon earlier regulations introduced in 2008 and now include dealers in precious stones and metals, as well as other adjacent products.
In late January, the Australian Transaction Reports and Analysis Centre (AUSTRAC) issued a nationwide communication to jewellery businesses titled ‘New financial crime laws coming – access our newly released kits to prepare.’
This guide, crafted for jewellery business owners, demystifies the changes and offers practical insights to protect your trade from illicit activities while maintaining operational efficiency. It's not just about ticking boxes – it's about fortifying your business against the $60.1 billion annual scourge of financial crime.
Australia's journey towards robust AML/CTF measures began in 2008 with Tranche 1, which targeted high-risk industries such as financial institutions, gambling, bullion dealers, and remittance services.
A 2015 review by the Financial Action Task Force flagged Australia as "partially compliant" with global anti-corruption standards, highlighting gaps that allowed financial crime to drain the economy.
Fast-forward to Tranche 2, effective 1 July 2026, and the net widens: real estate agents, lawyers, conveyancers, accountants, and dealers in precious stones, metals, and products are now in scope.
For jewellers, this means scrutinising transactions to avoid becoming unwitting conduits for money laundering or terrorism financing.
On the 23 January, AUSTRAC sent a Starter Kit email, tailored for jewellers including a document library and steps to customise, implement, maintain, and review your setup.
At its core, the legislation regulates businesses offering "designated services" with ties to Australia. If your operations involve buying or selling precious metals, gemstones, or products for $AUD10,000 or more in cash or virtual assets, you're included.
Precious metals include gold, silver, platinum, and alloys with at least two per cent of these elements. Precious stones encompass gem-quality varieties such as diamonds, opals, and pearls.
Precious products cover jewellery, watches, personal adornments, and goldsmith or silversmith wares – think a gold-and-pearl ring, a diamond-studded stainless-steel watch, or even dental jewellery such as a gold drill.
Businesses that provide one or more “designated services" that have a geographical link to Australia are regulated. Buying or selling precious metal, precious stones, precious products (or any combination of) for $AUD10,000 or more in physical currency or virtual assets.
• Precious Metals: Gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium or alloy with at least two per cent weight of any of the aforementioned.
• Precious Stones: Gemstone quality (including but not limited to) beryl, corundum, diamond, garnet, jadeite, jade, opal, pearl or topaz.
• Precious Products: Items made of, containing, or having attached to it any precious metals or stones (or both) that are any of jewellery, watches and other items of personal adornment, along with any article of goldsmith's or silversmith's wares.
Examples include: a ring crafted from gold and pearl, a stainless-steel watch with diamonds set on the face, a headdress made of platinum and garnet, and even a gold or diamond drill (dental jewellery).
Crucially, jewellery business owners must watch for "linked transactions." AUSTRAC views these as attempts to dodge thresholds, such as splitting a large deal into smaller payments under $AUD10,000, or multiple deals tied by the same invoice, payment method, or date. Ignoring these could turn routine sales into compliance nightmares.
Critical Reading: What you need to know
» AUSTRAC: Jeweller program starter kit
» AUSTRAC: Attention dealers in precious metals, stones & products
» AUSTRAC: Consequences of not complying
» AUSTRAC: Lists of enforcement actions taken
The Jeweller's Fork in the Road
Under new regulations, jewellery business owners face a serious choice with high-value cash deals: accept them and dive into full compliance, or decline and steer clear of regulatory burdens.
This decision hinges on your business model. Do large cash transactions drive your revenue, or can you pivot to alternatives?
Jewellers have two choices regarding transactions of $AUD10,000 or more in cash (or virtual assets):
Option #1: Do Not AcceptAvoid enrolling with AUSTRAC
and having reporting obligations. For many, the path of least resistance is avoidance. By refusing $AUD10,000 or more in cash payments, jewellery business owners can skip AUSTRAC registration, paperwork, and ongoing reporting. Communicating this policy diplomatically to customers will be important. Explain that post-COVID insurance no longer covers large cash holdings on-site or in transit, or highlight the security risks involved. Moreover, accepting cash is a big clerical workload for both parties due to the complex nature of adhering to AML/CTF requirements. Instead, guide consumers towards bank transfers. Hand over a pre-filled deposit form to smooth the process. Stay alert to structured or linked transactions that might sneak past thresholds; vigilance here prevents accidental breaches. By agreeing to no longer accept large cash transactions, jewellery business owners will not need to enrol, file forms, or meet reporting obligations. However, businesses will need to avoid linked transactions that total $10,000 or more in cash. | Option #2 : AcceptEnrol with AUSTRAC and
implement a compliance program. If cash-heavy deals are integral to your business, you will need to prepare for enrolment with AUSTRAC to meet reporting obligations. AUSTRAC's portal opens on 31 March 2026, with obligations commencing on 1 July. Complete registration by 29 July, aiming for full compliance by 31 August. You'll need to implement an AML/CTF Compliance Program for your business. AUSTRAC offers "Starter Kits" tailored for jewellers, including a document library and steps to customise, implement, maintain, and review your setup. Check the industry email from 23 January 2026 for links. » Key Dates for Compliance • 23 Jan 2026
Starter Kits mailed to jewellers
• 31 Mar 2026
Enrolment portal opens
• 1 Jul 2026
Obligations begin
• 29 Jul 2026
Enrolment deadline |
Practicalities matter: Weigh the point-of-sale hassle against the necessity of accepting $AUD10,000 or more in cash. For each qualifying transaction, the business will require the customer’s photo ID, perform a risk rating assessment, and conduct Customer Due Diligence (CDD) through onboarding, which includes a 13-page due diligence form.
High-risk clients, such as politically exposed persons, require additional checks on their wealth sources. Recording everything, conducting CDD on all such transactions, and submitting regular reports to AUSTRAC will be necessary. It's meticulous; however, it keeps your business legitimate.
Hard v Soft Opt-Out: What's the difference?
To prevent jewellery businesses from becoming involved in linked transactions, owners will have a choice between a 'hard' and 'soft' opt-out option. The differences between these options are outlined below:
Hard Opt-OutThe business does not accept any cash or virtual assets for jewellery purchases — all sales are by card, bank transfer, BPAY ad so on. A business elects not to be a reporting entity under the AML/CTF Act and therefore refuses to provide designated services that would trigger reporting obligations for cash or virtual-asset receipts. This eliminates risk of reaching the AUSTRAC cash/virtual-asset reporting threshold via single or linked transactions. While this is the strongest protection against linked-transaction risks, this may inconvenience customers and reduce some sales. » Retailers must implement: • Written No-Cash policy
• Staff training on refusal of the above assets for jewellery purchases $10,000 or higher
• Suggestions for alternative payment methods
• Keep a record of refused cash attempts | Soft Opt-Out (Recommended)The business accepts cash up to a defined low threshold per customer, and actively tracks cumulative cash received from each customer over AUSTRAC’s linking/look-back period. A business may opt out of reporting-entity status but must still implement a cash-acceptance policy that limits cash receipts per customer and includes monitoring to prevent aggregation of linked transactions that would otherwise trigger obligations. This provides a safety mechanism to avoid unintended linkage to the $10,000+ threshold while allowing limited cash transactions. While this helps to accommodate a customer's option with flexibility, it comes with risk control and requires monitoring and adherence to policy. » Retailers must implement: • Written cash policy (thresholds and refusal criteria)
• Staff training of processes to record and check cumulative cash receipts per customer
• Customer identification procedures when thresholds approach escalation/refusal protocols. |
All jewellers, whether choosing to enrol under the AML/CTF regime or to opt out, must put simple, practical controls in place ahead of the compliance date.
The reforms leave little room for guesswork, so failure to monitor cumulative cash receipts can turn routine sales into regulatory breaches. At a minimum, businesses should implement the following:
» Clear and visible cash policy: Draft a clear, accessible policy that states your position (Hard Opt Out or Soft Opt Out), defines cash and virtual-asset acceptance rules, and sets out refusal and escalation language staff must use. Keep it short, unambiguous and easy to follow and visible to all staff and customers.
» A reliable method to monitor cumulative cash per customer: You must be able to identify and sum up the total cash received from an individual over the relevant look-back period. Practical options include a dedicated POS flag, CRM note, manual log, or a simple spreadsheet for consistent record-keeping.
» Clear staff procedures for handling cash transactions: Spell out who records transactions, when to request ID, the trigger points for additional scrutiny, and the exact steps for refusing payment. Include standard scripts for staff to use when declining cash or asking for alternative payment methods.
» Training and routine audits: Provide training to front-of-house and sales staff on the policy and procedures, and run simple periodic audits to confirm the rules are being applied. Small businesses can use a weekly or monthly spot-check; larger retailers should integrate checks into existing compliance reviews.
These measures are practical and designed to protect both your customers and your business. While it will not remove all risk, they will ensure you can demonstrate a documented approach to managing cash and linked-transaction exposure.
Navigating these reforms isn't optional. It's essential for the jewellery industry's future. Choose your path wisely, train your staff on red flags, and integrate these practices into daily operations.
For those seeking additional information, Australia’s industry buying groups have organised an information session about these regulatory reforms.
Representatives from Nationwide Jewellers, Showcase Jewellers, and the Independent Jewellers Collective have attended multiple AUSTRAC industry briefings throughout 2025.
The groups will make the webinar available to all industry participants via Jeweller, providing access to the information for all business owners, not just buying group members. The seminar, which is free of charge, is scheduled for Tuesday, 10th March, 2pm.
Remember, this guide provides a broad overview; it's not a substitute for tailored legal or professional advice. Consult experts to align with your specific circumstances and ensure your business thrives in this new regulatory era.
Please check back for updates.
More reading
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How will new money laundering laws impact your jewellery business?
New money laundering laws: Millions at stake in the jewellery industry
New money laundering laws: What do jewellers need to know?
Money laundering & jewellery: Australia’s diamond-studded headache