AML Laws For Dealers In High-Value Goods

Australia’s Anti-Money Laundering and Counter-Terrorism Financing laws are changing, and businesses dealing in precious metals, precious stones and certain high-value products should be paying attention.

For jewellers, bullion dealers, diamond and gemstone dealers, auction-style businesses and some luxury goods sellers, the changes may affect how large transactions are handled - including customer verification, unusual payment methods, privacy notices, sales terms, refund controls, record keeping and staff escalation processes.

Many newly regulated businesses are expected to need to comply from 1 July 2026, so dealers in high-value goods should start reviewing their sales processes and legal documents before the new obligations commence.

This article explains what dealers in high-value goods should know and which legal documents may need to be reviewed.

Why AML Laws Matter For High-Value Goods Businesses

High-value goods can be attractive for money laundering because they can be expensive, portable and, in some cases, easier to resell than other assets.

Items such as jewellery, gold, diamonds, precious stones, luxury watches, art and collectables may be used to move or store value. While most customers will be completely legitimate, certain transactions may raise additional risk - for example, large cash purchases, split payments, third-party payments, unusual refund requests, delivery to an unrelated person, or purchases that do not match the customer’s explanation.

That is why affected businesses may need a clearer process for identifying higher-risk transactions, asking for information where required, keeping records and training staff on what to do if something seems unusual.

Are Dealers In High-Value Goods Covered By The New AML Laws?

Not every retailer or luxury goods business will be affected in the same way. AML/CTF obligations depend on the specific products, transaction values, payment methods and designated services involved.

Dealers in precious metals, precious stones and certain high-value products may need to assess whether their activities fall within the new AML/CTF regime. This may be relevant for jewellers, bullion dealers, diamond and gemstone dealers, and some other businesses dealing with high-value goods.

A practical starting point is to map the products and transaction types the business handles. For example, a jeweller selling lower-value retail items may have a different risk profile from a business regularly selling high-value diamonds, bullion or luxury watches to local and overseas customers.

Businesses should assess which products and transactions are in scope, out of scope or need further advice, and keep a record of the reasoning.

Large Transactions And Unusual Payment Methods

Large transactions are one of the most obvious AML risk areas for high-value goods businesses.

A customer buying a high-value watch, diamond ring, bullion product, artwork or luxury item may pay by bank transfer, card, cash, cryptocurrency, instalments, a third-party account, an overseas account or a combination of methods. Some payment methods will be ordinary for the business. Others may need closer attention.

For example, staff may need to escalate a transaction if a customer wants to pay a large amount in cash, split payments across several people or accounts, pay from an unrelated third party, use multiple cards without a clear reason, overpay and request a refund to a different account, or change payment arrangements at the last minute.

The point is not to treat every large transaction as suspicious. The point is to have a practical, risk-based process so staff know when extra checks are required.

If a high-value goods business accepts cryptocurrency, it may need separate advice on payment, tax, AML/CTF and digital asset risks.

Customer Verification And Due Diligence

Affected high-value goods businesses may need to verify certain customers before completing transactions, particularly where the transaction is high value or presents higher-risk indicators.

Customer verification may involve checking identity details, confirming whether the customer is buying for themselves or someone else, and asking questions about the nature or purpose of the transaction where appropriate.

For business customers, the process may involve confirming who owns or controls the company, who is authorised to purchase on its behalf, and whether the transaction fits the customer’s usual business activities.

This should be built into the sales journey in a practical way. For example, a jeweller may need a process for deciding when ID checks are required before releasing a high-value item. A bullion dealer may need onboarding steps before allowing large repeat purchases. An auction house may need verification steps before accepting high-value bids or releasing goods.

Online Sales, Auctions And Remote Customers

High-value goods are not always sold face to face. Many businesses sell through websites, online marketplaces, auctions, social media, private appointments, remote quoting processes or international enquiries.

Remote sales can create additional risk because the business may not meet the customer in person, may rely on uploaded documents, and may need to ship high-value goods to a third party or overseas address.

For example, a business may need to ask extra questions if the buyer’s payment details, billing address and delivery address do not match, if a bidder is participating remotely in a high-value auction, or if an online customer refuses to provide information required for verification.

If AML/CTF checks are built into online sales or auction processes, the business should make sure its website terms, auction terms, sales terms and privacy documents support that process.

Privacy Notices And Data Handling

AML checks can involve collecting more personal information than a high-value goods business would otherwise collect.

This may include identity documents, dates of birth, addresses, payment information, business details, beneficial ownership information, sanctions or screening results, and information about the purpose of a transaction.

A privacy policy should explain how the business collects, uses, stores and discloses personal information. A collection notice can be used at the point information is collected, such as when a customer is asked to provide ID for a high-value purchase or before bidding in an auction.

This is especially important if the business uses third-party verification providers, payment processors, fraud prevention tools, e-commerce platforms, auction platforms, cloud software, delivery providers or outsourced customer support.

Identity documents and payment information can be sensitive from a privacy and fraud-risk perspective. Businesses should think carefully about who can access that information, how long it is retained and how it is stored securely.

Sales Terms, Refunds And Customer Communications

Sales terms are a key document for dealers in high-value goods.

If the business may need to verify a customer, request additional information, verify payment details, delay delivery, refuse a transaction or cancel an order for compliance reasons, the sales terms should make that clear.

This is particularly important for high-value purchases where customers may expect immediate collection, delivery or transfer of ownership. If checks are required before goods can be released, the terms should help manage that expectation.

Refunds and returns also deserve attention. Sales terms may need to explain that refunds will usually be made to the original payment method, that additional checks may be required, and that the business may delay or refuse a refund where necessary to comply with law.

Customer-facing wording should also be careful. AML/CTF laws can involve tipping-off restrictions, so staff should avoid telling a customer that they are being reported or investigated. Neutral wording, such as “we need further information to complete our compliance checks”, may be more appropriate.

Record Keeping And Internal Escalation

For dealers in high-value goods, AML/CTF compliance will often depend on what happens at the point of sale.

Relevant records may sit across point-of-sale systems, invoices, payment records, e-commerce platforms, auction platforms, shipping records, email inboxes and identity verification tools. Affected businesses should have a clear process for storing and retrieving those records.

This may include records of customer checks, transaction details, payment information, refund decisions, delivery instructions, staff approvals and any internal escalations.

Staff should also know when to escalate a transaction. This might include large cash payments, split payments, third-party payments, reluctance to provide ID, unusual urgency, repeated high-value purchases, refund requests to unrelated accounts, inconsistent customer information, or delivery instructions that do not match the buyer’s details.

For a small jewellery store, bullion dealer or luxury goods business, this does not necessarily mean building a large compliance department. But it does mean having a practical process staff can follow when a transaction does not feel right.

What Should Dealers In High-Value Goods Do Now?

Dealers in high-value goods should start by reviewing the products they sell and the transactions they commonly handle. It can be useful to look at transaction size, payment methods, customer types, delivery methods, refund practices and whether the business deals with overseas customers, repeat buyers, intermediaries, agents or businesses.

From there, the business should map the sales journey. When is the customer identified? When is payment accepted? When are goods released? When are refunds processed? Who reviews unusual transactions? Where are records stored?

Once that process is clear, the documents supporting it should be reviewed. This may include sales terms, website terms, auction terms, invoice wording, refund policies, privacy policies, collection notices, customer onboarding forms, supplier or dealer agreements, contractor agreements, internal AML/CTF policies, escalation procedures, record-keeping policies and staff training materials.

The aim is to make sure the sales process works in real life - from the moment a customer asks to buy a high-value item, through to payment, release, delivery, refund requests and record keeping. If the business collects ID for high-value purchases, the privacy documents should explain why. If goods can be held while checks are completed, the sales terms should say so. If staff must escalate unusual payments, the internal policy should explain when and how to do that.

Affected businesses may also need broader AML/CTF readiness steps, including AUSTRAC enrolment or registration where required, appointing a compliance lead, conducting a risk assessment, implementing an AML/CTF program, training staff, keeping records and reporting suspicious matters where required. For higher-risk businesses, such as those dealing in bullion, precious stones, high-value international sales, auctions or frequent cash transactions, specialist AML/CTF compliance advice may also be needed.

FAQs

Do Jewellers Need To Comply With AML Laws?

It depends on the products and transactions involved. Jewellers dealing in high-value jewellery, precious stones, precious metals or large transactions may need to assess whether their activities are captured by the AML/CTF regime.

Why Are High-Value Goods Relevant To AML/CTF Compliance?

High-value goods can be used to move or store value. Items such as jewellery, gold, diamonds, luxury watches, art and collectables can be expensive, portable and potentially resold, which can create money laundering risk.

Do High-Value Goods Businesses Need To Verify Customers?

Affected businesses may need to verify customers for certain transactions, particularly where the transaction is high value or presents higher-risk indicators such as cash payments, third-party payments, overseas customers or unusual refund requests.

Should Sales Terms Be Updated?

They may need to be reviewed. Sales terms should support customer verification, requests for further information, delayed delivery, cancelled orders, refund controls and compliance-related communications where appropriate.

Are Legal Document Updates Enough For AML Compliance?

No. Legal document updates are only one part of AML/CTF readiness. Affected businesses may also need risk assessments, AML/CTF programs, staff training, escalation procedures, reporting processes and record-keeping systems.

How Sprintlaw Can Help

Sprintlaw can help dealers in high-value goods review and update the legal documents that support AML/CTF readiness.

This may include sales terms, website terms, auction terms, refund policies, privacy policies, collection notices, contractor agreements, supplier agreements and internal compliance policies.

For businesses that need a full AML/CTF program, risk assessment or specialist operational compliance advice, you may also need help from an AML/CTF compliance specialist. Sprintlaw can help make sure your legal documents align with the process you adopt.

Need help reviewing your legal documents before the AML/CTF changes take effect? You can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.