• Bullion Dealers

    Bullion Dealers are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Bullion Dealers

What are the ML/TF Risks?

Buying and selling high-value assets such as bullion is attractive for criminals because such transactions can avoid interaction with the financial sector.

Assets of this type may be easily hidden and can be transferred to third parties with limited documentation. In particular, criminals may buy such goods with cash (that is, physical currency) and give them to other parties to avoid detection.

Bullion may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CFT measures.

The Money Laundering and Terrorism Financing (ML/TF) risks associated with bullion dealers include:

  • Significant or frequent use of cash to purchase valuable commodities and assets, which can then be resold to disguise the origin of illicit funds;
  • Criminals may also use cash to buy high-value goods such as bullion, then travel overseas with them to transfer value while avoiding detection; and
  • Organised crime groups may use cash to purchase high-value goods then on-sell them for cash, so they can disguise the origin of the funds and deposit the money into the financial system.

Bullion, must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for the bullion dealers’ industry.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

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