We’ve created suspicious activity indicators for bullion dealers to help you identify potential money laundering, terrorism financing, proliferation financing and other serious criminal activities.
On this page
- Customer identification and behaviour
- Money laundering
- Terrorism financing
- Proliferation financing indicators
- Suspicious matter reporting
- Related pages
These indicators can inform your transaction monitoring alerts that trigger further review. To complement these indicators, you must also ensure your transaction monitoring systems alert you to unusual, large or complex transactions or patterns of transactions.
This indicators list isn’t exhaustive. You should consider other indicators specific to your business’s individual risk profile and circumstances.
Customer identification and behaviour
Read our list of suspicious activity indicators for customer identification and behaviour.
Customer identification indicators
A customer:
- provides identification information that’s false, misleading, vague or cannot be verified
- refuses or is reluctant to provide identification information or documents
- is identified in adverse media
- provides a billing or delivery address which is in a different region or country from their residential address
- has sources of wealth or sources of funds that are unexplained or inconsistent with their profile (for example, students and government payment recipients)
- uses a post office box or private service provider’s address, instead of providing a residential address.
Customer behaviour indicators
A customer:
- makes an unusual enquiry to staff about whether they report to government authorities. For example, AUSTRAC, the Australian Taxation Office or law enforcement agencies
- enquires about transaction limits or requests their transaction not be reported
- is the subject of law enforcement enquiries, or their activity is
- appears nervous, overly defensive or evasive when questioned
- requests to be anonymous
- refuses to provide details about why they are buying bullion
- asks questions about reporting and identification thresholds or requests advice on how to avoid them
- appears to be directed by a third party. For example, the customer refers to information by or is accompanied by another person, or appears coached or rehearsed when answering questions
- is uninterested in the details of the purchase, such as the price, transaction fees, delivery cost or storage fees
- refuses to provide identification documents
- has a third party collect the bullion on their behalf.
Money laundering
Read our list of suspicious activity indicators for money laundering.
Money laundering indicators
A customer:
- buys and sells bullion frequently at a loss
- purchases high value bullion or pays invoices using large sums of cash
- breaks down transactions into smaller amounts to avoid the $5,000 customer identification threshold or the $10,000 transaction reporting threshold. For example, smaller payments over consecutive days or across multiple branches
- attempts to over- or under-value the purity or weight of the bullion, misclassify the metal, misrepresent the price, quantity or quality of the bullion or disguises its origin
- chooses a payment method (such as a credit card) that incurs fees rather than an alternative method that doesn’t incur fees
- divides payments for bullion into electronic transfers, cheques, smaller cash transactions or cash deposits
- makes frequent payment deposits via methods where it’s difficult to determine the source of funds. For example, e-wallets, cryptocurrencies, EFTPOS gift cards etc.
- splits bullion purchases with another person to reduce the visibility of the transaction
- purchases multi-kilo amounts of bullion over an unusually short period
- makes multiple bullion purchases over a short timeframe
- has an account which is paid by a third party
- requests bullion to be shipped to jurisdictions designated as ‘high risk’ for money laundering or terrorism financing activities
- makes multiple transactions over a short timeframe involving foreign nationals
- states the bullion is to be taken overseas after it’s purchased
- who is not within the bullion or jewellery industry and has a number of companies registered to them or recurrently uses business accounts to pay for bullion
- who is a non-permanent resident of Australia purchases bullion in amounts they can conveniently and discreetly transport overseas.
Other indicators:
- individual bullion dealers are linked to known or suspected criminals or criminal groups
- a jewellery business purchases bullion in quantities exceeding what you consider normal for a business of their size and may pay invoices using cash
- a jewellery business frequently sells jewellery to your business and then uses the profits to purchase bullion.
Terrorism financing
Read our suspicious activity indicators for terrorism financing:
- a customer is matched through screening against an Australian or international sanctions list
- open-source information identifies a customer has links to known terrorist organisations or terrorism activities
- open-source information indicates a customer displays extremist ideologies. For example, social, political or environmental.
Proliferation financing indicators
Proliferation financing is when a person makes available an asset, provides a financial service or conducts a financial transaction that’s intended to facilitate the proliferation of weapons of mass destruction, regardless of whether the activity occurs or is attempted.
A customer:
- is matched through screening against an Australian or international sanctions list
- requests bullion to be moved to jurisdictions designated as high risk for proliferation financing
- enquires about due diligence processes when transacting with individuals, networks, companies or countries of proliferation concern
- uses complex company or trust structures to obscure the source and beneficial ownership of funds
- conducts business in dual use goods listed on the Defence and Strategic Goods List
- is connected to industries with higher proliferation financing risks. This includes but is not limited to those identified in Australia’s proliferation financing national risk assessments and the Australian Sanctions Office advisory note on sanctions and proliferation financing.
Corporations:
- share directors and management, addresses, emails, phone numbers or financial infrastructure with other entities in their networks
- obscure their identities and activities by:
- using aliases and using alternate spellings or versions of company names
- using subsidiaries or branches
- including third-country nationals in corporate structures
- registering in jurisdictions with opaque corporate registers, where information on ultimate beneficial ownership isn’t easily accessible.
Suspicious matter reporting
If you suspect on reasonable grounds that a customer or a transaction involving your customer is linked to a crime, submit a suspicious matter report (SMR) to us within the required timeframes. This includes where you suspect on reasonable grounds that a person:
- is committing a crime
- isn’t who they claim to be
- could be the victim of a crime.
On their own, one of these indicators may not suggest suspicious activity. If you’re unsure whether there are reasonable grounds for a suspicion, you should conduct further monitoring and examination. This may include applying enhanced customer due diligence (ECDD) measures.
For more information on complying with your reporting obligations, see our suspicious matter reporting reference guide and suspicious matter reporting checklist.
Related pages
This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened.
The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.
This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.