AMLify's Supplier Due Diligence for Precious Metals Dealers
AMLify now screens suppliers and refiners for precious metals and stones dealers, extending AML/CTF due diligence beyond the retail counter.
AMLify has released supplier and sourcing due diligence tools for Australian precious metals and stones dealers, screening bullion suppliers and refiners for sanctions exposure so dealers can meet AML/CTF Act 2006 obligations on both sides of every transaction.
Why does supplier risk matter for precious metals dealers?
Most Tranche 2 guidance for this sector focuses on the customer at the counter, but laundering risk can enter from the supply side too. A supplier offering metal below market rate, an unregistered scrap refiner, or a cross-border sourcing relationship with weak provenance records can expose a dealer to laundered proceeds without a retail customer being involved. AUSTRAC treats sourcing risk as a legitimate input into a dealer's ML/TF risk assessment, and CDD obligations under the AML/CTF Act 2006 extend to any party to a designated service -- not only the person paying at the counter.
What new supplier screening features has AMLify released?
- Supplier sanctions and PEP screening -- checks each supplier and their beneficial owners before onboarding
- Origin and refiner verification checklist -- records where metal or stones were sourced and which refiner processed them
- Cross-border sourcing risk scoring -- flags suppliers routing through jurisdictions AUSTRAC or FATF treat as higher-risk
- Scheduled re-screening -- re-checks existing suppliers on a rolling basis, not only at onboarding
- Supplier records in the audit trail -- screening results sit alongside customer CDD records in one exportable file
How does the screening work in practice?
When a new supplier is added, AMLify runs an automated sanctions and PEP check and returns a result before the relationship goes live. Where a supplier crosses jurisdictions AUSTRAC flags as higher-risk, the origin checklist prompts staff to record supporting documentation -- invoices, refiner certificates, or export permits -- to justify the relationship if AUSTRAC ever asks. AMLify surfaces the risk and the evidence trail; the compliance officer still makes the call.
How does this fit into an existing AML/CTF programme?
Supplier screening feeds the same ML/TF risk assessment AMLify already builds for customer-side CDD, so a dealer isn't running two separate processes. Existing AMLify customers in this sector can turn it on in Settings without reconfiguring their programme; new customers get it enabled by default. See pricing for plan details.
Key Takeaways
- Sourcing risk is now covered -- AMLify screens suppliers and refiners, not just retail customers
- Sanctions and PEP checks run automatically, with scheduled re-screening of existing suppliers
- A guided origin checklist captures documentation for higher-risk sourcing relationships
- Results feed the same risk assessment used for customer CDD, avoiding duplicate processes
- Existing customers can enable it in Settings -- no programme reconfiguration required
Frequently Asked Questions
Q: Do AML/CTF obligations apply to a dealer's suppliers, not just customers?
Yes, in effect. A supply relationship where a dealer buys metal or stones can itself be a designated service requiring CDD. Even where it isn't, AUSTRAC expects a dealer's risk assessment to cover laundering risk arising anywhere in the business, including through suppliers.
Q: What counts as a higher-risk sourcing relationship?
Common indicators include suppliers in or routing through jurisdictions with weak AML controls, refiners that can't produce provenance documentation, and pricing well below prevailing market rates. AMLify's risk scoring surfaces these patterns; the final rating is a judgement call for the compliance officer.
Q: Does supplier screening replace the need for a written AML/CTF programme?
No. It's one control within a broader programme. Every Tranche 2 reporting entity still needs a documented Part A and Part B AML/CTF programme, an ML/TF risk assessment, and ongoing customer due diligence alongside any supplier-side controls.
This is general information only and not a substitute for legal advice.