Buying and selling high-value assets such as bullion is attractive for criminals because such transactions can avoid interaction with the financial sector.

Assets of this type may be easily hidden and can be transferred to third parties with limited documentation.

Criminals may buy such goods with cash (that is, physical currency) and give them to other parties to avoid detection.

Bullion dealers may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CTF measures.

The Money Laundering and Terrorist Financing (ML/TF) risks associated with the bullion dealers sector include:

  • The significant or frequent use of cash to purchase valuable commodities and assets, which can then be resold to disguise the origin of illicit funds

  • Criminals may also use cash to buy high-value goods such as bullion, precious metals and gems, then travel overseas with them to transfer value while avoiding detection

  • Organised crime groups may use cash to purchase high-value goods then sell them for cash, so they can disguise the origin of the funds and deposit the money into the financial system without raising red flags

Bullion dealers captured by the AML/CTF obligations must ensure their organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures. This is a critical first step in complying with AML/CTF Act and Rules.

The AML/CTF regime is risk-based, which means that your responses to the AML/CTF obligations placed upon you should be risk-based.

A risk-based AML/CTF regime requires that you understand and address the Money Laundering and Terrorism Financing (ML/TF) risks associated with the services you offer.

You must then design, implement and maintain systems, procedures and controls that are proportionate to your ML/TF risks.

With over 50 years of expert knowledge and real world experience our AML/CTF compliance solutions will to help you navigate your legal and regulatory requirements so that your business complies with its AML/CTF obligations in the fastest and most cost-effective way.

Costos has a range of AML/CTF solutions to support your business in becoming AML/CTF compliant and maintaining compliance.