AMLify Adds Buy-Back Compliance Workflow for Dealers

AMLify's new buy-back workflow captures seller ID and item provenance when precious metals dealers purchase scrap gold or jewellery from the public, closing a gap in coverage for the highest-risk side of a dealer's counter.

What does the new buy-back intake workflow do?

When a dealer buys scrap gold, secondhand jewellery, or bullion from a walk-in seller, AMLify now prompts for the seller's identity documents, a description and photo of each item, and a short source-of-item declaration before the purchase can be recorded as complete. The record is timestamped and stored against the seller's CDD file, so a repeat seller builds a visible history instead of each visit starting from a blank slate.

Why is buying from the public the highest-risk side of the counter?

Most Tranche 2 guidance for this sector has focused on the sale — verifying who is buying bullion or jewellery. But a buy-back counter is where a dealer converts an item into cash on the spot, which makes it an attractive way to launder proceeds of crime or offload stolen goods. AUSTRAC's guidance treats CDD obligations under the AML/CTF Act 2006 as applying to both sides of a designated service, and a dealer who only verifies buyers has left the higher-risk half of the business unmonitored.

How does the workflow work in practice?

The intake process runs in four steps: 1. Capture seller ID — a driver's licence or passport is verified against an independent source before the purchase proceeds 2. Record item details — description, weight or carat, and a photo are attached to the transaction 3. Log a source-of-item declaration — the seller states how they came to own the item, in their own words 4. Auto-check the cash threshold — any cash payment of AUD 10,000 or more is flagged into AMLify's existing TTR workflow, and same-seller payments are aggregated to catch structuring

What happens when a seller triggers a red flag?

A seller who is reluctant to produce ID, gives a vague or inconsistent source-of-item explanation, or returns repeatedly with similar items is flagged to the AMLCO's dashboard rather than waved through. The AMLCO can escalate the case into AMLify's suspicious matter report (SMR) workflow, which must be lodged with AUSTRAC within 24 hours of a reasonable suspicion forming. The tipping-off prohibition still applies — the seller must not be told a report has been made. See the full sector workflow on the AMLify precious metals dealers page.

Key Takeaways

• AMLify now runs a dedicated intake workflow for buy-back transactions — capturing seller ID, item details, and a source-of-item declaration at the point of purchase
• Buy-back is the higher-risk side of the counter — it converts goods to cash instantly, and AUSTRAC expects CDD on sellers, not just buyers
• Cash thresholds and structuring checks run automatically, feeding into AMLify's existing TTR and SMR workflows
• Repeat sellers build a visible history in their CDD file instead of each visit being assessed in isolation
• The workflow is included in AMLify's standard plan — see /pricing for the 14-day free trial

Frequently Asked Questions

Q: Does AMLify's buy-back workflow apply to every purchase from the public?

It applies to any purchase of precious metals, precious stones, or jewellery containing them from a member of the public, regardless of transaction size. The identity verification and source-of-item declaration steps run before the purchase can be recorded as complete.

Q: How is this different from AMLify's existing supplier due diligence feature?

Supplier due diligence screens business suppliers and refiners a dealer sources bullion from. The buy-back workflow covers the separate scenario of buying scrap gold or secondhand items directly from members of the public, which carries a different risk profile and requires its own CDD steps.

Q: What happens if a seller can't produce photo ID?

The purchase cannot be completed until identity is verified against an independent source. AMLify flags any attempted workaround, such as a seller offering to complete the transaction under someone else's name, as a red flag for AMLCO review.

Q: Does a buy-back purchase still need a cash transaction report?

Yes. A cash payment of AUD 10,000 or more that a dealer pays out to buy an item triggers the same threshold transaction reporting obligation as cash received from a sale, and AMLify's TTR workflow applies equally to both directions.

This is general information only and not a substitute for legal advice.

Related articles