What AUSTRAC's First DPMS Compliance Reviews Are Finding
Five weeks after the Tranche 2 deadline, AUSTRAC's first DPMS compliance checks are surfacing the same gaps. Here is what reviewers are flagging.
AUSTRAC's earliest compliance checks on dealers in precious metals and stones (DPMS) since the 1 July 2026 Tranche 2 deadline are turning up the same handful of gaps: risk assessments that never mention buy-backs or scrap gold, threshold transaction reports lodged late, and customer files with no source-of-item evidence at all.
Why is AUSTRAC reviewing DPMS businesses so soon after the deadline?
DPMS has long been rated a high-risk sector by FATF and by AUSTRAC's own sector risk assessments — precious metals and stones are portable, liquid, and hold high value in a small parcel, making them an established vehicle for laundering proceeds of crime. Cash-heavy counters, pawn arrangements, and buy-back desks make an obvious early focus once enrolment numbers confirmed who was actually trading.
What are reviewers actually asking for?
- Proof of enrolment — a current, correctly registered AUSTRAC reporting entity number
- A named, empowered AMLCO who can show real oversight, not just a title
- A risk assessment specific to the dealer — buying, selling, and buy-back transactions, not a generic template
- CDD files — identity and source-of-item or source-of-funds evidence for high-value sales and purchases
- TTR records proving every cash transaction of $10,000 or more was lodged within 10 business days
What gaps are showing up most often?
- Generic risk assessments with no mention of scrap gold, buy-backs, or pawn transactions specific to the dealer's actual stock
- No structuring checks — repeat customers splitting cash payments below $10,000 going unflagged
- CDD skipped for "regular" customers, on the assumption a known face doesn't need identification or a source-of-item check
- TTRs lodged past the 10-business-day window, or not lodged at all for cash buy-backs
What should a dealer do if AUSTRAC makes contact?
Respond within the timeframe given and be upfront about gaps rather than papering over them — AUSTRAC treats a dealer who co-operates and remediates in good faith very differently from one that misrepresents its position. AMLify's compliance tools for precious metals and stones dealers keep risk assessments, CDD evidence, and TTR records in one exportable place.
Key Takeaways
- Early reviews check whether a programme is actually operating, not just whether documents exist
- Generic risk assessments are the most common gap — reviewers expect the dealer's actual buy-back and pawn activity to be addressed specifically
- Structuring and "regular customer" CDD shortcuts are a recurring red flag
- Late or missing TTRs draw scrutiny fast, since the 10-business-day obligation is automatic and easy for AUSTRAC to verify
- Co-operating and remediating quickly is treated far more favourably than concealing gaps
Frequently Asked Questions
Q: How soon after the Tranche 2 deadline could AUSTRAC review a DPMS business?
There is no minimum waiting period. AUSTRAC can review any enrolled reporting entity providing a designated service, and its early Tranche 2 activity has focused on confirming DPMS businesses actually operationalised their obligations rather than just registering.
Q: Does a small independent jeweller face the same scrutiny as a large bullion dealer?
The AML/CTF Act 2006 applies regardless of size, though AUSTRAC expects the programme to be proportionate to risk and scale. A small jeweller still needs a risk assessment, an AMLCO, and CDD records, just scaled to a smaller operation.
Q: What happens if TTRs were lodged late before AUSTRAC made contact?
Late lodgement is a contravention of the AML/CTF Act 2006. If a historical delay is discovered, document it, lodge any outstanding reports immediately, and fix the underlying process — a self-identified gap that's promptly remediated is treated far more favourably than one uncovered during a review.
Q: Can gaps be fixed after AUSTRAC has already been in touch?
Yes, and AUSTRAC's guidance encourages it. Remediating promptly after a review request is viewed far more favourably than having no plan at all, though it does not erase the fact that the original gap existed.
This is general information only and not a substitute for legal advice.