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For jewellers and bullion dealers

Tranche 2 AML/CTF compliance for jewellers and bullion dealers

Jewellers and bullion dealers have faced wider AML/CTF obligations under Tranche 2 since 1 July 2026. Every threshold cash transaction, every cross-border movement, and every high-risk customer needs a verified record before the transaction completes. duely runs the check at the counter.

What makes Tranche 2 hard for jewellers and bullion dealers

Cash transactions, cross-border movements, and long-running customer relationships all generate compliance obligations that don't fit a generic template.

High-value cash transactions

Jewellers and bullion dealers see legitimate cash buyers regularly. Transactions at or near the TTR threshold need structured capture, not informal logs, and the regulator expects to see the record on demand.

Cross-border movements

Valuable items moving across borders trigger Cross-Border Movement (CBM) reporting obligations for physical currency or BNIs ≥ $10,000. CBM is a separate AUSTRAC report type that's easy to miss without dedicated workflow.

Repeat customer risk patterns

Long-standing customer relationships can drift over time as buying patterns change. Spotting unusual purchase clusters or sudden high-value buys requires structured ongoing CDD, not just goodwill memory.

Inventory provenance

Provenance, sourcing, and chain-of-custody questions intersect with conflict-mineral and sanctioned-supplier concerns. Sanctions and PEP screening at customer onboarding is one part of the answer.

What's available now and what's coming

The jeweller template pack, TTR / CBM capture, and the core compliance workflows are live. Jeweller-specific cash-handling guidance and inventory-provenance workflows are opening in phases. Each item below is tagged honestly so you know exactly what your firm gets today.

Jeweller template pack

Available now

duely ships with a jeweller-aligned policy template and designated-service catalog, so your firm's AML/CTF program starts with the right scaffolding rather than a blank page.

  • Jeweller-specific designated service definitions
  • AUSTRAC-aligned policy template tuned for jeweller and bullion practice
  • Pre-populated risk and CDD scaffolding to customise
  • Faster path from sign-up to a defensible AML/CTF program

Matter-first compliance

Available now

Every customer engagement gets its own compliance unit, scoping, parties, risk, evidence, independent of every other matter on your books.

  • Separate matters per customer engagement
  • Independent compliance lifecycle per matter
  • Scoping for each jeweller engagement type
  • Full audit trail per matter, not just per client

TTR and CBM capture

Available now

Both transaction-based AUSTRAC report types, Threshold Transaction Reports for ≥ $10,000 cash and Cross-Border Movement reports for currency / BNIs crossing borders, have structured capture workflows that link back to the relevant matter.

  • TTR capture workflow for cash transactions at threshold
  • CBM capture for physical currency / BNIs crossing borders
  • Matter-linked transaction records for compliance evidence
  • Structured AUSTRAC-aligned report data capture

Risk-based CDD with sanctions and PEP screening

Available now

Onboard customers with structured identity verification, sanctions, and PEP screening, proportionate due diligence based on customer and transaction risk.

  • Identity verification with safe harbour, non-safe harbour, and manual paths
  • Sanctions and PEP screening at onboarding and on demand
  • Risk-based CDD calibration
  • ECDD triggers when high-risk indicators are present

Audit-ready evidence packs

Available now

Generate tamper-evident evidence packs for any matter, with role-based Standard and AMLCO-only Sensitive profiles.

  • Versioned evidence packs with per-version SHA-256 integrity hashing
  • Two profiles by role: Standard (default) and AMLCO-only Sensitive
  • Complete decision trail: decision, rationale, timestamp, and approver
  • Export-ready snapshots for regulatory review or internal audit

Jeweller-specific cash-handling workflows

On the roadmap

Jeweller-tuned cash-handling guidance, repeat-customer cash pattern detection, structuring indicators, retail-counter scenarios, is in development. The general TTR capture workflow and risk wizard are available now.

  • Jeweller-tuned cash pattern guidance (in development)
  • Structuring-indicator decision support (in development)
  • Available now: general TTR capture workflow
  • Available now: general matter-level risk wizard with ECDD triggers

Inventory provenance and supplier screening

On the roadmap

Supplier-side screening and inventory-provenance workflows tied to conflict-mineral and sanctioned-supplier concerns are on the roadmap. Customer-side sanctions and PEP screening is available now.

  • Supplier-side sanctions screening (in development)
  • Inventory provenance recording tied to matters (in development)
  • Available now: customer-side sanctions and PEP screening
  • Available now: matter-level evidence trail for purchasing decisions

Build a defensible jeweller compliance file from day one

Start with the jeweller template pack and let the platform structure scoping, CDD, TTR / CBM reporting, and evidence around every transaction.