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October 4, 20269 min read

Linked transactions for bullion dealers

Linked transactions mean a bullion dealer does not treat one purchase as several smaller ones. This page names that idea; it does not show how to split a sale.

Quick answer

If the customer is buying one quantity of precious metal and the invoices are cut into pieces, the pieces can be one transaction for reporting. Your program should say how you notice that. This page will not explain how to structure sales to stay under a threshold. The threshold rules are a different article; customer due diligence is still a separate check.

People search “precious metals AML Australia” when a bullion dealer rings up three smaller invoices for what was one purchase. Checked against AUSTRAC’s threshold transaction report page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The threshold article is the threshold transaction report. The sector page is Tranche 2 for precious metals. The sector map is /tranche-2.

One purchase, even if the till prints three

Precious metals AML in Australia includes the idea of linked transactions because a single bullion purchase can be written as several receipts. The reporting question is whether those receipts are one physical-currency transaction broken into parts. A dealer that always invoices a large buy as three smaller ones should assume the program needs a way to see the link. The staff member on the counter is not free to decide that the till tape is the law.

This page will not explain how to split a sale, how to time deposits, or how to word an invoice so a threshold is missed. That would be the opposite of the rule. AUSTRAC’s threshold transaction page is the official source. This article does not reproduce it and does not restate the dollar line; if you need the threshold figure and who files, use the threshold article; customer identification stays the program’s CDD, not a substitute for a report.

  • See one purchase. Several receipts for one buy are a link question. They are not three unrelated customers.
  • Write the link in the program. Staff need a rule for same-day, same-customer bullion sales. This page does not draft that rule.
  • Do not teach a split. Nothing here explains how to stay under a threshold. Do not ask the page for that.
  • Keep CDD separate. Identifying the customer does not replace a report the threshold rules require.

What linking is for

A recognition aid for bullion receipts. This table does not reproduce AUSTRAC’s threshold rules or a method of splitting sales.

PatternTreat it asDo not treat it as
One buyer, one quantity, three invoicesA link question for the programThree sales that cannot be reported
Three unrelated buyersThree customers, if they are realA link you force so the paperwork looks neat
A request to invoice under a lineA reason to escalate inside the shopInstructions this page will finish
A completed customer checkCDD onlyA substitute for threshold reporting

Where this page stops

This page is the link idea. It is not the jeweller orientation. That page is AML for jewellers.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Showing a dealer how to split invoices is not a service, and a threshold report is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not show you how to split a sale or decide that invoices are separate.

Frequently Asked Questions

Linking sales is a program rule. The check is client-pays.

The firm suite is A$0. The client pays KYC or KYB. A threshold report is not that product.

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Questions: team@freeaml.com.au