Threshold Transaction Reporting for Precious Metals Dealers

Precious metals and stones dealers in Australia face a threshold transaction reporting obligation that is more specific — and more demanding — than many Tranche 2 businesses realise. Under the AML/CTF Act 2006, every transaction involving $10,000 or more in physical currency must be reported to AUSTRAC within 10 business days, regardless of whether the dealer suspects anything is wrong. Now that Tranche 2 has commenced, dealers who accept any cash need a working threshold transaction reporting workflow built into their daily operations, not just a written programme on a shelf.

What Is a Threshold Transaction Report?

A Threshold Transaction Report (TTR) is a statutory report that a reporting entity must lodge with AUSTRAC whenever a customer transacts using $10,000 or more in physical currency — Australian or foreign. The obligation is automatic: it does not depend on whether the transaction is suspicious or whether the customer raises any concern. If the cash threshold is met or exceeded, the TTR must be lodged, even where enhanced due diligence has been completed and the transaction appears entirely legitimate.

Which Dealers Must Lodge Threshold Transaction Reports?

The TTR obligation applies to reporting entities that receive physical currency while providing a designated service. For precious metals and stones dealers, the relevant designated service is buying or selling precious metals, precious stones, or jewellery in the course of business. A dealer that accepts $10,000 or more in physical currency from a single customer in connection with a single transaction — or a series of related transactions — must lodge a TTR for each occasion the threshold is met. The obligation applies equally to sole traders, retail jewellers, bullion dealers, and wholesale precious stones businesses.

What Counts as Physical Currency for TTR Purposes?

Physical currency means banknotes and coins in Australian dollars or any foreign currency. It does not include: - Electronic funds transfers — bank transfers, BPAY, OSKO, or SWIFT payments - Credit or debit card payments — point-of-sale card or EFTPOS transactions - Cheques — including bank cheques and personal cheques - Digital assets — cryptocurrency payments (separate obligations may apply to virtual asset service providers) Dealer principals sometimes assume that receiving a bank cheque for $50,000 of bullion triggers a TTR — it does not. Only physical banknotes and coins count. However, a non-cash payment of that magnitude may still warrant enhanced due diligence or, where suspicious circumstances exist, a Suspicious Matter Report.

How Do Aggregation Rules Apply to Dealers?

The AML/CTF Act 2006 contains anti-structuring rules that require reporting entities to aggregate related transactions. Where a customer makes multiple cash payments that are individually below $10,000 but are connected — for example, paying $6,000 on Monday and $5,000 on Thursday for what is effectively one purchase — the amounts are treated as a single transaction and the combined total triggers a TTR. Indicators that transactions may be related include: - The same customer making multiple payments within a short timeframe - Payments that together constitute one underlying deal, even where split across visits or instalments - Customer behaviour suggesting threshold awareness — for example, requesting that a purchase be split into separate invoices to keep each payment below $10,000 Deliberate structuring to avoid the reporting threshold is itself a money laundering red flag that warrants immediate escalation to the AMLCO and, in most cases, a Suspicious Matter Report.

What Information Must a Threshold Transaction Report Include?

A TTR lodged via AUSTRAC Online must contain: 1. Date and time of the transaction 2. Amount of physical currency received and the currency type (AUD or foreign) 3. Customer identification — full name, date of birth, address, and the verification document used under the dealer's KYC procedures 4. Business details — the dealer's ABN, legal name, and the relevant premises or branch 5. Nature of the transaction — the type of purchase or sale and the goods involved (for example, gold bullion, diamond jewellery, platinum coin) 6. Third-party details — if someone other than the customer physically provides the cash, their identifying details must be included where known This is why customer due diligence and TTR lodgement must be operationally integrated: the identification information required in the report must be collected and verified at the time of the transaction, not reconstructed after the sale is completed.

When Must a TTR Be Lodged?

The TTR must be lodged with AUSTRAC within 10 business days of the day the transaction occurred. For a cash sale finalised on a Monday, the deadline is the Monday of the following fortnight, adjusted for public holidays. There is no extension for delayed identification, system outages, or staff absence — the 10-business-day clock starts on the transaction date, not the date the dealer decides to report. Dealers should build TTR preparation directly into their sales process so that customer details are captured at point of sale and the report can be queued immediately rather than pieced together later from incomplete records.

TTRs vs Suspicious Matter Reports: What Is the Difference?

Dealers frequently conflate threshold reporting with suspicious matter reporting. They are separate and independent obligations: - Threshold Transaction Reports (TTRs) must be lodged automatically whenever a cash transaction meets or exceeds $10,000 — suspicion is irrelevant. Every qualifying transaction must be reported without exception. - Suspicious Matter Reports (SMRs) must be lodged when the dealer has reasonable grounds to suspect a transaction involves proceeds of crime, tax evasion, financing of terrorism, or another designated offence. There is no minimum dollar amount: a $500 cash purchase can trigger an SMR if the circumstances warrant it. The two obligations can overlap. A $15,000 cash bullion purchase that the dealer suspects involves undisclosed criminal proceeds requires both a TTR (the threshold is met) and an SMR (the suspicion exists). Lodging the TTR does not discharge the SMR obligation, and vice versa — both must be filed independently within their respective timeframes.

Key Takeaways

• Every cash transaction of $10,000 or more must be reported to AUSTRAC within 10 business days — the obligation is automatic and does not require any suspicion
• Only physical currency counts — bank transfers, EFTPOS, and cheques do not trigger a TTR, though high-value non-cash transactions may still warrant enhanced due diligence or an SMR
• Aggregation rules apply — related cash payments below $10,000 that together meet the threshold must be combined and reported; deliberate structuring is a red flag requiring an SMR
• CDD and TTR workflows must be integrated — the identification information required in a TTR must be collected at the time of sale, not reconstructed after
• Get compliant now — dealers who accept physical currency need a working TTR process in place before the deadline, not just a written programme

Frequently Asked Questions

Q: Do precious metals dealers need to report all large transactions, or only cash ones?

Only physical currency — banknotes and coins in Australian or foreign currency — triggers the threshold transaction reporting obligation. A dealer selling $200,000 of gold bullion paid entirely by bank transfer has no TTR obligation for that transaction. Electronic transfers, card payments, and cheques of any size do not trigger a TTR. However, large non-cash transactions may still require enhanced due diligence under Part B of the AML/CTF Programme, and suspicious circumstances surrounding any transaction — regardless of payment method — may require a Suspicious Matter Report.

Q: What happens if a dealer misses the 10-business-day lodgement window?

Late or missed TTR lodgements are a contravention of the AML/CTF Act 2006. AUSTRAC treats TTR compliance as a core indicator of a reporting entity's programme effectiveness — a pattern of late reports, or a dealer who handles cash but has never lodged a TTR, is likely to attract supervisory attention and can result in civil penalties, enforceable undertakings, or formal investigation. If a historical lodgement failure is discovered, document it, lodge the overdue report as soon as practicable, and review the internal process to prevent recurrence. A self-reported gap that is promptly remediated is treated more favourably than one uncovered during an AUSTRAC examination.

Q: Can a customer send someone else to make a cash payment on their behalf?

Yes, and third-party payment arrangements require additional care. Where someone other than the named customer physically provides the cash, the TTR must include identifying details for both the customer and the third party, to the extent those details are known. The arrangement should also prompt enhanced due diligence — third-party cash payments are an established money laundering red flag because they can obscure the true source of funds and the identity of the beneficial owner of the goods being purchased. A dealer whose Part B programme does not include a specific procedure for third-party cash payments has a material compliance gap.

Q: How does the $10,000 threshold apply when a dealer both buys from and sells to the same customer on the same day?

The threshold applies separately to each occasion on which physical currency changes hands. Where a customer sells scrap gold to the dealer for $8,000 cash and then buys jewellery for $6,000 cash in the same visit, neither individual transaction meets the threshold on its own. However, where the dealer nets the two transactions and pays the $2,000 difference in cash, the analysis depends on whether the netted arrangement constitutes a single transaction in substance. Dealers with buy-sell business models should document in their AML/CTF Programme exactly how same-customer, same-day cash offsets are treated so the threshold calculation is applied consistently and can withstand AUSTRAC scrutiny.

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

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