What the Tranche 2 Deadline Passing Means for Metals Dealers

The Tranche 2 deadline of 1 July 2026 has passed, which means dealers in precious metals and stones are now fully regulated entities under the AML/CTF Act 2006 -- not businesses preparing for a future obligation. If enrolment, a risk assessment, or a working AML/CTF programme aren't in place yet, the priority is closing that gap immediately, not perfecting it.

Are Precious Metals and Stones Dealers Still Required to Enrol Now the Deadline Has Passed?

Yes. Enrolment with AUSTRAC did not expire on 1 July -- it became a standing legal requirement for any dealer providing a designated service, and operating without it is itself a breach. A dealer who missed the deadline should enrol immediately rather than wait for a more convenient time, since the obligation only grows more visible with every transaction processed unregistered.

What Should Dealers Prioritise in the Weeks After the Deadline?

1. Confirm AUSTRAC enrolment is complete and business details are accurate, including all trading names used at the counter.
2. Finalise the ML/TF risk assessment, naming dealer-specific risks such as cash-heavy bullion sales, structuring, and third-party buyers.
3. Embed customer due diligence at the $10,000 threshold, covering walk-in customers as well as repeat trade accounts.
4. Train frontline staff to recognise red flags and to know when a transaction requires escalation.
5. Test the suspicious matter reporting channel so the first real SMR isn't also the first time the process has been used.

What Happens If a Dealer Still Hasn't Enrolled or Enrolled Late?

AUSTRAC has said its early Tranche 2 focus is education and supervised remediation rather than immediate penalties, but that grace period narrows the longer a dealer stays unenrolled. Civil penalty provisions under the AML/CTF Act 2006 remain available for non-compliance, and a dealer identified during an early compliance review with no programme in place is a far weaker position to be in than one that self-reports gaps and shows a remediation plan already underway.

How Can Dealers Catch Up Quickly Without Cutting Corners?

Speed matters, but a rushed programme built from a generic template creates its own risk -- AUSTRAC expects a risk assessment calibrated to what a dealer actually trades, whether that's bullion, loose stones, or set jewellery. AMLify for precious metals and stones dealers generates a programme and CDD workflow matched to a dealer's real product mix and automatically flags cash transactions at or above the reporting threshold, so catching up doesn't mean starting from a blank page.

Key Takeaways

• The 1 July 2026 deadline passing did not remove the obligation to enrol -- it made non-enrolment a live breach
• Confirming enrolment, finalising the risk assessment, and embedding CDD at $10,000 are the immediate priorities
• AUSTRAC's early focus is remediation, but civil penalties under the AML/CTF Act 2006 remain available
• A generic, templated programme is weaker evidence of compliance than one calibrated to a dealer's actual stock
• AMLify builds a dealer-specific programme and CDD workflow to close gaps quickly

Frequently Asked Questions

Q: Is it too late for a precious metals or stones dealer to enrol with AUSTRAC?

No. Enrolment is not a one-time deadline that closes -- it's an ongoing legal requirement. A dealer who missed 1 July 2026 should enrol as soon as possible; delaying further only increases the compliance gap AUSTRAC will see during any review.

Q: Will AUSTRAC penalise a dealer immediately for enrolling late?

AUSTRAC has indicated its early supervisory approach favours education and remediation over immediate enforcement, but civil penalty provisions under the AML/CTF Act 2006 still apply, and a documented remediation plan is far better evidence than no programme at all.

Q: Does a risk assessment written for a bullion dealer also cover a jewellery or gemstone dealer?

Not adequately. AUSTRAC expects a risk assessment to reflect the specific products and customer base a dealer actually handles -- treating loose gemstones the same as gold bullion overlooks risks specific to each.

Q: What is the cash transaction reporting threshold dealers need to monitor?

Dealers must apply customer identification and threshold transaction reporting to cash transactions of $10,000 or more, and structuring a purchase across multiple smaller payments to stay under that threshold is itself a red flag.

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

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