bullion aml ctf policy

Who This Policy Applies To

This policy applies to all customers, transactions, and designated bullion services provided by Bradford Coins & Stamps. Under Australian AML/CTF law, designated services include buying and selling qualifying precious metals, such as:

• Gold, silver, platinum, and palladium bullion bars, ingots, and wafers.
• Gold and silver bullion coins valued primarily by their metal weight (e.g., Gold Sovereigns, Krugerrands).
• Other qualifying investment-grade precious metal items.

Note: Numismatic collectors' coins, proof sets, and rare coins are evaluated separately based on rarity, market value, and condition.

For detailed identity verification requirements, please read our KYC Policy.

Customer Due Diligence & $5,000 Exemption Rules

Customer Due Diligence (CDD) helps us verify customer identities and assess transaction risk levels. The depth of verification depends on the customer type, transaction value, and risk profile.

Bullion Transactions Under $5,000 AUD

In accordance with AUSTRAC bullion dealer guidance, a limited exemption from initial Customer Due Diligence applies to a bullion transaction only when both conditions are met:

1. The retail value of the bullion bought or sold is less than $5,000 AUD.
2. The transaction or customer profile does not require Enhanced Customer Due Diligence (EDD).

If Enhanced Customer Due Diligence is triggered by risk factors, initial identity verification must be completed regardless of the transaction amount.

Enhanced Due Diligence, PEPs & Sanctions

When a transaction or customer presents a higher financial crime risk, we conduct Enhanced Customer Due Diligence (EDD). This may involve:

• Collecting additional primary identification or corporate control documents.
• Verifying the Source of Funds (origin of money used for the trade) and Source of Wealth (how overall assets were accumulated).
• Screening customers against Politically Exposed Persons (PEPs) lists and international financial sanctions registers.
• Increasing transaction monitoring or reassessing whether the business relationship can continue.

AUSTRAC Reporting Duties

1. Threshold Transaction Reporting (TTR)

We are legally required to file a Threshold Transaction Report with AUSTRAC for any transaction involving $10,000 AUD or more in physical cash (banknotes and coins, including foreign currency equivalents).

2. Anti-Structuring Protection

Splitting transactions into smaller installments to avoid the $10,000 cash reporting limit or $5,000 bullion verification limit is illegal under Australian law and will be investigated.

3. Suspicious Matter Reporting (SMR) & Tipping Off

If we have reasonable grounds to suspect that a transaction involves financial crime, identity fraud, or tax evasion, we promptly submit a Suspicious Matter Report to AUSTRAC. Under strict Australian anti-tipping-off provisions, we are legally prohibited from informing customers if an SMR has been submitted or reviewed.

Transaction Suspension, Security & Record Keeping

• Refusal of Service: We reserve the right to delay, decline, or suspend any transaction if required identification is withheld, identity cannot be verified, or AML/CTF risks are unmanageable.
• Record Retention: Customer identity documents, risk assessments, and transaction logs are stored in secure physical and electronic systems for a minimum of 7 years in compliance with Australian statutory rules.

Contact Bradford Coins & Stamps

If you have questions regarding our AML/CTF procedures, compliance rules, or identification requests, please contact our team: