Tranche 2 AML/CTF compliance for jewellers and bullion dealers
Since 1 July 2026, Tranche 2 has widened the AML/CTF obligations of jewellers and bullion dealers. Every threshold cash transaction, cross-border movement and high-risk customer needs a verified record before the transaction completes. duely runs the check at the counter.
How a sale runs in duely
The screens your team works in
These are real screens from duely, with sample data. The app calls each sale an engagement.
Verify and screen.Identity and screening results sit side by side for each person, with the date and the method used.
Rate the risk.The answers produce a rating and show what drove it. A High rating opens enhanced due diligence.
Approve.An approver signs off before the work goes ahead. The approval stays on the record.
Generate the pack.One PDF, whenever you need it. Each version has its own SHA-256 hash, so any later change to the file can be detected.
What makes Tranche 2 hard for jewellers, and how duely handles it
Jewellers and bullion dealers see transaction patterns other sectors do not. duely captures them without slowing the counter.
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High-value cash transactions
Jewellers and bullion dealers regularly serve legitimate cash buyers. Transactions at or near the threshold transaction report (TTR) threshold need a structured record, not an informal log, and AUSTRAC expects to see it on request.
A report record for every threshold cash sale
Flag cash at the $10,000 threshold and duely captures the threshold transaction report (TTR) details against the sale. Your team lodges it with AUSTRAC and records the reference. See AUSTRAC reporting
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Cross-border movements
Cross-border movement (CBM) reports cover physical currency and bearer negotiable instruments (BNIs) of $10,000 or more carried, sent or received across the border, not gold, bullion or jewellery. CBM is a separate AUSTRAC report and easy to miss without its own workflow.
Cross-border movement capture
Cross-border movement reports for physical currency or bearer negotiable instruments (BNIs) have their own capture workflow, linked back to the sale.
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Repeat customer risk patterns
Long-standing customers' buying patterns can change over time. Spotting clusters of unusual purchases or a sudden high-value buy takes structured ongoing CDD, not memory and goodwill.
Onboard once, assess every sale
Each customer is onboarded once and every sale gets its own risk assessment. Daily monitoring checks queue screening that has gone stale. See the engagement workflow
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Inventory provenance
Provenance, sourcing and chain of custody overlap with conflict-mineral and sanctioned-supplier concerns. Screening customers for sanctions and politically exposed persons (PEP) at onboarding is one part of the answer.
Sanctions and PEP screening
Customers are screened for sanctions and politically exposed persons (PEP) at onboarding and on demand, with proportionate due diligence based on risk. See screening sources
Your customer verifies on their own phone
Send a link. They give consent, scan an ID document and take a selfie, and the result lands on their record. Nobody has to come into the office.
- Takes about a minute
- An ID check and a face check, both on their phone.
- Documents from 200+ countries
- Identity documents from more than 200 countries and territories.
- Done once
- Each customer's due diligence is reused on every sale.
Also live now, and what's still coming
Jeweller template pack
duely includes a policy template and designated service catalogue written for jewellers, so your AML/CTF program starts from a working draft, not a blank page.
Audit-ready evidence packs
Generate a tamper-evident evidence pack for any engagement. Two profiles control what each role sees: Standard, and the AMLCO-only Sensitive profile.
Jeweller-specific cash-handling workflows
Cash-handling guidance tuned for jewellers is in development: repeat-customer cash patterns, structuring indicators and retail-counter scenarios. The general TTR capture workflow and risk wizard are available now.
Build a defensible jeweller compliance file from day one
Start with the jeweller template pack. duely then organises CDD, TTR and CBM capture, and evidence around every transaction.
