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.

Trust and Company Service Providers (TCSPs) can take different forms, but generally assist in the creation, operation and management of corporate and trust structures.

The services offered by TCSPs operate as a gateway to property and financial markets, financial institutions and other regulated professionals. These can be misused by criminals to disguise beneficial ownership, conceal the origins and purposes of financial transactions, facilitate tax evasion and, ultimately, launder the proceeds of crime, as well as, where complex structures are established, create distance between criminal entities and their illicit wealth.

The Money Laundering and Terrorist Financing (ML/TF) risks associated with the TCSP industry include:

• Obscuring ultimate ownership through complex layers and legal entity structures
• Evading tax and exploiting known tax shelters
• Evading regulatory controls
• Providing a veneer of legitimacy to criminal activity by helping to conceal proceeds of crime
• Creating distance between criminal entities and their illicit income or wealth by using complex business and corporate structures
• Avoiding detection and confiscation of assets, and hindering law enforcement investigations

Trust and company service providers 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 the AML/CTF Act and Rules.

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