FINTRAC Compliance for Dealers in Precious Metals & Precious Stones

FINTRAC Obligations for Precious Metals and Stones Dealers

If you buy or sell precious metals (gold, silver, platinum, palladium) or precious stones (diamonds, rubies, sapphires, emeralds) in the course of your business, you are a reporting entity under the PCMLTFA. Your obligations are triggered by the nature of the goods you trade and the cash-intensive environment in which many of these transactions occur.

Precious metals and stones have long been used as a vehicle for money laundering because they are portable, high-value, and can be traded outside the conventional banking system. FINTRAC pays close attention to this sector, and your compliance program needs to reflect that reality.

What You Must Report

Large Cash Transaction Reports (LCTR)

File an LCTR when you receive $10,000 or more in cash in a single transaction, or when multiple cash transactions from the same client total $10,000+ within a 24-hour period. In this industry, large cash purchases are common, making LCTR filing a regular obligation rather than an occasional one.

Deadline: 15 calendar days.

Suspicious Transaction Reports (STR)

File an STR when you have reasonable grounds to suspect a transaction is related to money laundering or terrorist financing. Red flags specific to your industry include:

• Clients who purchase high-value items with cash and show no interest in the quality, grade, or certification of the goods
• Transactions where the stated purpose does not match the buyer's apparent profile
• Requests to break a single purchase into multiple smaller cash payments
• Clients who buy and immediately resell items at a loss
• Purchases by third parties on behalf of unnamed buyers

Deadline: As soon as practicable.

Client Identification

You must verify the identity of every person who conducts a transaction of $3,000 or more. For cash transactions at or above $10,000, enhanced identification measures apply.

Industry-Specific Compliance Challenges

• Cash-heavy environment: Many transactions in precious metals and stones are conducted in cash, particularly at the wholesale and trade levels. The volume of cash transactions means LCTR obligations are frequent, and 24-hour aggregation rules must be applied consistently.
• Walk-in clients and one-time transactions: Unlike banks or brokerages where clients have established accounts, many precious metals and stones transactions involve walk-in buyers. Identifying and verifying clients who may never return creates a compliance friction point that is unique to this industry.
• Valuation and structuring detection: Clients who want to launder money through precious metals often structure purchases to stay just below the $10,000 cash threshold. Recognizing structuring patterns across multiple visits or transactions requires systematic tracking, not just point-of-sale awareness.
• Cross-border considerations: Precious metals and stones are globally traded. Clients may be purchasing goods for export or importing items for resale. These cross-border dimensions add complexity to your risk assessment and customer due diligence obligations.

How Comply+ Helps

Cash Transaction Monitoring

Upload your daily sales data. Comply+ automatically identifies every cash transaction that meets the LCTR threshold, aggregates transactions within your 24-hour window, and generates pre-filled reports.

STR Detection for High-Value Goods

Our aiSTR technology flags transactions that match risk indicators specific to precious metals and stones: structuring patterns, purchases inconsistent with buyer profiles, rapid buy-sell cycles, and cash-intensive activity from first-time clients.

Client Identification Records

Comply+ maintains a searchable database of client identification records, linking each client to their transaction history. When FINTRAC examines your business, your documentation is complete and organized.

Direct FINTRAC Submission

Submit LCTRs and STRs directly to FINTRAC from within the platform. Every submission is tracked with confirmation receipts and a full audit trail.

Record Keeping Requirements

FINTRAC publishes official guidance on record keeping for dealers in precious metals and precious stones. For full details and current requirements, see: Record keeping requirements for dealers in precious metals and precious stones (FINTRAC).