AML/CTF · Precious Metals

Cash Is King in Your Business — Which Is Exactly Why AUSTRAC Is Watching | AML/CTF DPMS Australia 2026

Published 1 April 2026Last reviewed June 20265 min readBy Paul Wise

Every precious-metals business knows cash is part of the trade. What fewer owners have absorbed since the Tranche 2 reforms commenced on 1 July 2026 is that the same cash intensity that makes the business work also makes it a standing priority for AUSTRAC enforcement.

Why DPMS is a high-priority sector

Money launderers love what jewellers and bullion dealers handle: portable, high-value goods that hold value, convert easily back to cash, and don't ask questions. Add anonymous or walk-in buyers and a culture of cash settlement, and you have a classic vehicle for cleaning illicit funds — including through trade-based money laundering, where the goods themselves move value across a chain of transactions.

That's not a slur on the industry. It's precisely why the regime captured DPMS (s 6(3), Table 2 of the AML/CTF Act), and why regulators expect this sector to take monitoring seriously rather than treat it as paperwork.

The reports you owe

Two obligations matter most day to day:

  • Threshold Transaction Reports (TTRs): transactions involving $10,000 or more in physical currency must be reported to AUSTRAC under section 43 of the Act within 10 business days. For DPMS, this is the same cash line that makes the transaction a designated service — so your "regulated" deals and your "reportable" deals largely coincide.
  • Suspicious Matter Reports (SMRs): anything that gives you reasonable grounds to suspect money laundering, terrorism financing or other serious crime must be reported under section 41 — regardless of dollar value, and even if the deal never completes. SMRs are generally due within 3 business days of forming the suspicion (24 hours where it relates to terrorism financing).

The red flag most staff miss: structuring

The pattern that trips up cash businesses is structuring (also called smurfing): deliberately breaking one large transaction into several smaller ones to stay under the $10,000 threshold. Deliberately conducting transactions to avoid the reporting requirements is itself an offence under section 142 of the Act — and, as AUSTRAC stresses, "linked or apparently linked" transactions are counted together toward the threshold anyway.

Watch for these patterns: a customer buying $9,000 in bullion today then returning tomorrow for another $9,000; several "different" buyers paying cash for the same high-value item; multiple payments under one invoice around the same date; a buyer who suddenly loses interest the moment ID is requested; purchases that don't fit the customer's apparent profile.

The problem is obvious in hindsight and almost invisible in real time — because the suspicious part is the pattern across transactions, not any single sale. You can't expect a counter assistant to be a financial-crime analyst tracking who bought what last Tuesday.

Let the system do the analysis

This is the core job of Veriqua's Transaction Monitoring module with AI Triage. Instead of relying on staff to remember and connect cash transactions across days and customers, Veriqua automatically flags structuring and smurfing patterns for review. The AI Triage layer surfaces the transactions that actually warrant a closer look and quietens the noise — so your team escalates the right ones and gets on with serving customers.

In other words: your staff don't have to become money-laundering experts. The platform watches the pattern, flags the anomaly, and gives you a defensible, timestamped record that you were monitoring — which is exactly what AUSTRAC expects to see.

See the monitoring in action in two minutes, no login: demo.veriqua.com.au/start.

Frequently Asked Questions

What is a Threshold Transaction Report (TTR) for jewellers and bullion dealers?
A TTR is a report you must lodge with AUSTRAC within 10 business days whenever you receive $10,000 or more in physical cash in a single transaction (or linked transactions that total that amount). TTRs are threshold-based — they apply automatically once the cash amount is met, regardless of suspicion. For DPMS, the TTR threshold coincides with the designated service trigger, so most regulated sales are also TTR-reportable.
When must a precious metals dealer lodge a Suspicious Matter Report (SMR)?
When you have reasonable grounds to suspect that a client or transaction is connected to money laundering, terrorism financing or another serious offence — regardless of the dollar value, and even if the transaction never completes. The standard is objective: would a reasonable person in your position form the same suspicion? SMRs are due within 3 business days (24 hours for terrorism financing).
What is structuring and why is it illegal in Australia?
Structuring (smurfing) is deliberately breaking a transaction into smaller amounts to avoid the $10,000 reporting threshold. Section 142 of the AML/CTF Act makes conducting transactions specifically to avoid the reporting requirements a criminal offence. AUSTRAC counts linked or apparently linked transactions together toward the threshold, so structuring achieves nothing except criminal exposure.
How do I detect structuring in my jewellery or bullion business?
Manual detection is unreliable because the suspicious part is the pattern across transactions, not any individual sale. Effective detection requires transaction monitoring software that tracks cash transactions across days and customers and flags patterns automatically. Warning signs to brief staff on include: repeated just-under-threshold purchases, multiple buyers for the same item, reluctance to provide ID, and transactions that don't match the customer's apparent purpose.

See how Veriqua handles this

Veriqua is an Australian compliance operating system for AFSL holders and AUSTRAC reporting entities — automating AML/CTF programs, customer due diligence, transaction monitoring, SMR lodgement and board reporting.

Disclaimer: This article is general information only and is current as at June 2026. It reflects our understanding of the AML/CTF reforms and AUSTRAC guidance as at that date, which may change. It is not legal, financial or compliance advice and must not be relied on as such. Whether a specific transaction must be reported depends on its facts. If you are ever unsure whether a matter must be reported, seek advice promptly — the timeframes are short. Refer to current AUSTRAC guidance at austrac.gov.au before acting.