Indicators of suspicious activity for bullion dealers

During the course of business, if you suspect that a customer or transaction is linked to a crime, you are required to submit a suspicious matter report to AUSTRAC.

This list of indicators will help you identify circumstances that could be suspicious in nature or that could indicate that money is being laundered or used for terrorism financing purposes.

The list is not exhaustive and you should consider other indicators specific to your business’s individual risk profile and circumstances. AUSTRAC has a suspicious matter reporting reference guide and a suspicious matter reporting checklist to help you ensure your SMRs are effective.

You can also download this information as a Quick guide for bullion dealers (PDF, 678KB).

Payment indicators

  • Purchasing bullion or paying invoices using cash
  • Breaking 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
  • Dividing payments into electronic transfers, cheques, smaller cash transactions or cash deposits
  • Frequent payment deposits via methods where it is difficult to determine the source of funds e.g. e-wallets, cryptocurrencies, EFTPOS gift cards etc
  • Splitting bullion purchases with another person to reduce the visibility of the transaction
  • Purchasing multi-kilo amounts of bullion over an unusually short period
  • Making multiple purchase transactions over a short timeframe

Customer identification issues

  • Identification documents are either false or questionable; or identity details differ from payment details
  • Customer is identified as a politically exposed person, or linked to one
  • Customer is linked to adverse crime related media
  • Customer is matched through screening against an Australian or international sanctions list
  • Customer is a member of, or linked to a known terrorist organisation
  • Source of wealth or source of funds is unexplained and/or inconsistent with their profile (for example: students and government payment recipients)
  • Post office box or private service provider’s address is used, instead of providing a residential address
  • Customer provides a billing or delivery address which is in a different region or country from their residential address

Behavioural indicators

  • Shows signs of nervousness, is hurried or vague, requests to be anonymous, or 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
  • Uninterested in the details of the purchase, such as the price, transaction fees, delivery cost or storage fees
  • Chooses a payment method (such as a credit card) that incurs fees rather than an alternative method that does not incur fees
  • Attempts to over or under-value the purity and/ or weight of the bullion, misclassify the metal, misrepresent the price, quantity or quality of the bullion or disguises its origin

International indicators

  • Non-permanent residents of Australia purchases bullion in amounts they can conveniently and discreetly transport overseas
  • Request for bullion to be shipped to jurisdictions designated as ‘high-risk’ for money laundering or terrorist financing activities
  • Multiple transactions over a short timeframe involving foreign nationals

Business indicators

  • Jewellery business purchases bullion in quantities exceeding what you consider normal for a business of their size, and may pay invoices using cash
  • Frequently sells jewellery to your business and then uses the profits to purchase bullion
  • Customer who is not within the bullion or jewellery industry has a number of companies registered to them or recurrently uses business accounts to pay for bullion

The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.

Last updated: 24 Mar 2023
Page ID: 805

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