Anti-Money Laundering for the Precious Metals, Jewellery & Art Trade

Gold, gemstones, jewellery and art retain their value, are easy to transport and can be resold anonymously – which is exactly what makes them attractive to money launderers. The legislator has therefore set particularly low thresholds for these industries.

Thresholds at a glance

BusinessObligations from
Trading in precious metals such as gold, silver and platinumCash payments of €2,000 or more
Trading in other goods, e.g. jewellery, watches, gemstonesCash payments of €10,000 or more
Trading, brokering or storing works of artTransactions of €10,000 or more – regardless of the payment method
Any transaction with grounds for suspicionAlways, regardless of the amount

Once a threshold is reached, risk management (risk assessment, internal safeguards) and the general due diligence obligations apply. Where trading in high-value goods is the main activity, the supervisory authority should also order the appointment of an AML officer (Section 7(3) GwG).

Typical risks

  • Purchasing scrap gold or jewellery of unclear origin (also a risk of handling stolen goods)
  • Splitting cash purchases just below €2,000 or €10,000
  • Art purchases via intermediaries, freeports or offshore companies
  • Conspicuous valuations and quick resales
  • Links to sanctioned persons or high-risk countries
Outlook 2027: Under the EU Anti-Money Laundering Regulation, a cash limit of €10,000 applies from 10 July 2027; for dealers in certain high-value goods, identification obligations are planned from €3,000 in cash.

Organising purchasing and sales in a legally sound way

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Your contact person

Badge Certified Corporate Compliance Specialist (CCCS)

Alen Gruber
Certified Corporate Compliance Specialist
External AML Officer

info@gruber-partner.de

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