Dealers of precious metals and stones
In addition to other red flags, we have identified the following specific red flags relevant to our business and industry:
- Customer indiscriminately purchases merchandise without regard for value, size, or colour.
- Purchases or sales that are unusual for customer or supplier.
- Unusual payment methods, such as large amounts of cash, multiple or sequentially numbered money orders, traveller's checks, or cashier’s cheques, or payment from third-parties.
- Attempts by customer or supplier to maintain high degree of secrecy with respect to the transaction, such as request that normal business records not be kept.
- Customer is reluctant to provide adequate identification information when making a purchase.
- Transactions that appear to be structured to avoid reporting requirements.
- A customer orders item, pays for them in cash, cancels the order and then receives a large refund.
- A customer asking about the possibility of returning goods and obtaining a cheque (especially if the customer requests that cheque be written to a third party).
- A customer paying for high-priced jewellery or precious metal with cash only.
- A customer not asking for the reduced price or haggling over the list price.
- Purchase appears to be beyond the means of the customer based on his stated or known occupation or income.
- Customer may attempt to use a third party cheque or a third party credit card.
- Funds come from an offshore financial centre rather than a local bank.
- Large or frequent purchases made in funds other than local currency.
- Transaction lacks business sense.
- Purchases or sales that are not in conformity with standard industry practice.
Wholesalers and suppliers of precious metals and stones
In addition to other red flags, we have identified the following specific red flags relevant to our business and industry:
- Over or under-invoicing.
- Overly structured or complex requests.
- Multiple invoice requests.
- High-value shipments that are over or underinsured.
- Unwillingness by a supplier to provide complete or accurate contact information, financial references or business affiliations.
- Counterpart presence, such as an affiliated store or branch or associate, in non-cooperative countries and territories or country that has a higher risk rating.
Bullion dealers
In addition to other red flags, we have identified the following specific red flags relevant to our business and industry:
- Purchasing bullion or paying invoices using cash
- Breaking down transactions into smaller amounts to avoid the $5,000 customer identification threshold in Australia, or the $10,000 transaction reporting threshold. For example, smaller payments over consecutive days or across multiple branches
- Splitting bullion purchases with another person to reduce the visibility of the transaction
- Purchasing multi-kilo amounts of bullion over an unusually short period
- Shows signs of nervousness, is hurried or vague, requests to be anonymous, or refuses to provide details about why they are buying bullion
- Attempts to over or under-value the purity and/ or weight of the bullion, misclassify the metal, misrepresent the price, quantity or quality of the bullion or disguises its origin
- Non-permanent residents of Australia purchases bullion in amounts they can conveniently and discreetly transport overseas
- Request for bullion to be shipped to jurisdictions designated as ‘high-risk’ for money laundering or terrorist financing activities
- Multiple transactions over a short timeframe involving foreign nationals
- Jewellery business purchases bullion in quantities exceeding what you consider normal for a business of their size, and may pay invoices using cash
- Frequently sells jewellery to your business and then uses the profits to purchase bullion
- Customer who is not within the bullion or jewellery industry has a number of companies registered to them or recurrently uses business accounts to pay for bullion
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