What counts as bullion
AUSTRAC describes bullion as authenticated gold, silver, platinum or palladium valued by the metal’s market price. It can include bars and coins. A coin traded for its bullion value differs from a collector coin valued for other features, although the latter may fall under precious-metals rules. The customer need not take physical possession: stored holdings and dealer-managed pools can be relevant. Private buying or selling is not the designated business service. These distinctions make product, valuation and business capacity important scope facts.
The initial CDD exemption has two conditions
The bullion guidance gives an initial CDD exemption where the retail value is less than $5,000 and enhanced CDD is not required. Both conditions matter. It is not a general exemption from all AML obligations and should not be confused with the cash reporting threshold. If enhanced CDD is required, initial CDD applies regardless of the bullion value. This distinction answers a common practical question: product value, payment method and customer risk are separate facts that can lead to different obligations.
- Retail value
The cited initial CDD exemption requires a retail value below $5,000.
- Enhanced CDD
The exemption also requires that enhanced CDD is not required.
- Other duties
Do not use this exemption as a cash-reporting threshold or a release from all AML duties.
Value and enhanced CDD are separate checks
Read this visual with the source conditions and explanation in this section.
Decision checkpoints. Read the conditions for each point in the text below.
Worked example: changed delivery instructions
Imagine a customer pays for a product but asks for delivery to a different person at a new address. In the example, staff record the change and follow the business process for confirming authority and purpose. There may be a legitimate explanation. The reviewer should not treat a gift or third-party delivery as proof of crime. Equally, the original customer record may not answer the new question. The case note identifies the evidence considered and the reason for the next action.
Separate cash reporting from product scope
The example dealer also identifies how payment was made. Product classification and cash reporting are different questions. A record that says high-value item does not establish whether a threshold cash report is required. Staff need the service and payment facts before applying the relevant rule. Other TTR conditions and exceptions still need checking. Use the dedicated reporting guidance for the legal test. Do not assume that an electronic payment removes all other customer or monitoring obligations.
Check records across the sale
A practical review can trace a fictional transaction from the product record to customer information, payment and delivery. Ask whether changes remain visible and whether a reviewer can understand who authorised them. If records sit in separate systems, identify the references that connect them. This check can reveal operational gaps without claiming that a particular system is required by law. For a live program, use the current detailed guidance. This sector explanation offers a route to that work and does not confirm that a dealer is compliant.