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AUSTRAC Tranche 2 AML/CTF Obligations (2026)

AML/CTF Obligations for High‑Value Dealers

Under Tranche 2 reforms, high‑value dealers — including bullion traders, luxury goods sellers, art dealers, vehicle dealers, and other high‑value traders — are now captured under the AML/CTF Act. This page explains exactly what you must do to comply.

Learn more in the AML/CTF Guide.

When Are High‑Value Dealers Captured Under Tranche 2?

You are captured if you deal in **high‑value goods**, including:

Precious metals (gold, silver, platinum)

Precious stones (diamonds, gemstones)

Luxury watches, jewellery, and designer goods

High‑value motor vehicles

Boats, aircraft, or collectible vehicles

Fine art, antiques, and rare collectibles

Bullion trading and storage services

Large cash or high‑risk transactions

If you buy, sell, trade, or store high‑value goods, you must comply with the AML/CTF Act — even if you are a small or family‑run business.

What High‑Value Dealers Must Do to Comply

1. AML/CTF Programme (Part A & B)

You must maintain a written AML/CTF Programme outlining governance, risk assessment, controls, and CDD procedures.

2. ML/TF Risk Assessment

You must assess the money laundering and terrorism financing risks associated with your clients, goods, and transactions.

3. Customer Due Diligence (CDD)

You must verify client identity, understand the purpose of the transaction, and apply enhanced due diligence for high‑risk clients.

4. Suspicious Matter Reporting (SMR)

You must report suspicious matters to AUSTRAC within 3 business days (or 24 hours for terrorism‑related matters).

5. Record Keeping

You must keep AML/CTF records, CDD evidence, and SMR logs for at least 7 years.

6. Ongoing Monitoring

You must monitor client activity, update risk assessments, and review your AML/CTF Programme annually.

See full requirements in the AML/CTF Guide.

How AML Shield Pro Helps High‑Value Dealers

AML Shield Pro is purpose‑built for high‑value dealers, bullion traders, luxury goods sellers, and art dealers. It generates your AML/CTF Programme, ML/TF Risk Assessment, CDD templates, SMR logs, and audit‑ready documents — all in under an hour.

AML/CTF Programme Builder

Generate Part A & B automatically.

Risk Assessment Builder

Identify and score ML/TF risks.

CDD Templates

Verify clients and store evidence.

SMR Logging

Track suspicious matters with timestamps.

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