AMLR-ready compliance for jewellers and precious metals & stones dealers

The €10,000 EU cash cap

An EU-wide limit of €10,000 on cash payments for commercial transactions — whether paid as a single operation or as a series of linked ones. A customer cannot split one purchase into smaller cash payments to stay under the cap, and your staff need to spot the attempt when it happens.

CDD on cash from €3,000

Occasional cash transactions of €3,000 or more trigger limited customer due diligence. That catches a large share of everyday trade for a jeweller or bullion dealer — a sale that once needed nothing beyond a receipt now needs an identity check on file.

Your competent authority

The AMLCU (Department of Justice) is the AML competent authority for high-value goods dealers, alongside TCSPs and unaffiliated accountants. It monitors your compliance and can inspect your AML programme, risk assessment and customer files.

Sanctions with more teeth — now in force

An administrative financial sanctions regime for the AMLCU’s sectors is in force since 30 June 2026 (S.I. No. 307 of 2026) — before the AMLR applies. Enforcement has sharpened ahead of 2027, which makes a tidy, evidenced AML file worth having now, not later.

CDD at €10,000 occasional transactions

Customer due diligence for occasional transactions kicks in at €10,000, down from €15,000. A single high-value sale to a walk-in customer now needs identity verification on file — not just a receipt.

Linked transactions count together

Both the CDD thresholds and the cash cap apply to a single operation or a series of linked ones. Three payments of €4,000 for one purchase is one €12,000 transaction. Your staff need to recognise a linked series at the counter.

The 25% rule for corporate customers

When you sell to a company, a beneficial owner is anyone holding 25% or more of it, directly or indirectly — harmonised EU-wide. Before entering a new business relationship with a corporate customer you must obtain an RBO extract and report discrepancies between the register and what you find (Reg 20(3)(b), SI 110/2019).

STR dual reporting stays

Suspicious Transaction Reports are dual-reported in Ireland: to FIU Ireland via the goAML portal, and to the Revenue Commissioners via ROS as an XML upload. Your MLRO must be registered on both.

Retain five years — then delete

The AMLR requires records to be retained for five years and then deleted. Keeping every customer file forever is no longer compliant; your business needs a defensible deletion process as well as good record-keeping.

Fast, structured onboarding for walk-in and repeat customers, with KYC identity verification through Didit — so a €10,000 sale doesn’t stall while someone hunts for a photocopier.

Automatic warnings at the €10,000 cash cap and the €3,000 occasional-cash CDD trigger, built into your client and transaction flows — including linked operations — so the till catches it before it becomes a breach.

Screen customers and beneficial owners against the EU consolidated financial sanctions list, UN listings and PEP datasets via OpenSanctions — at onboarding and on an ongoing basis, with a full decision log.

Generate a Business-Wide Risk Assessment and AMLR policy pack mapped to Regulation (EU) 2024/1624 — written for a jeweller or bullion dealer, not a bank, including the prescribed compliance-role designations.

Build the STR record, export goAML-compatible XML for upload to goAML and Revenue ROS, and track both submission dates and acknowledgements. CompliDesk prepares and records — your MLRO files.

Every customer file, check and decision sits on an audit trail, with a staff training log alongside — and the AMLR’s five-years-then-delete retention rule built into how records are kept.