Dealers in Precious Metals and Stones (DPMS)
Canada's small, mid and large-scale precious metals and stones dealers — luxury jewellers, bullion and coin dealers, wholesalers, auction houses, and multi-location retailers — face a distinct compliance profile under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). As a Dealer in Precious Metals and Stones (DPMS), your obligations are narrower than a bank's, but the stakes are not: high-value, high-volume transactions attract attention from FINTRAC, and increasingly from the banks and payment processors your business depends on to move money.
Note, if your business is trading any sort of precious metal or jewelry over $10,000 you may be considered a DPMS.
In practice, a stalled account review or a hesitant correspondent bank disrupts operations more than a FINTRAC examination ever will. The AML Shop designs and reviews AML compliance programs built for the realities of DPMS operations — multi-location retail, wholesale and supply relationships, high-ticket transactions, and the banking relationships that keep them running smoothly.
Who is a Dealer in Precious Metals and Stones?
Under the PCMLTFA and its regulations, you're a Dealer in Precious Metals and Stones if, in the course of business, you buy or sell precious metals — gold, silver, platinum, palladium — or precious stones such as diamonds, sapphires, emeralds, rubies, tanzanite, and alexandrite, where a transaction (or a series of related transactions) reaches $10,000 CAD or more. That definition casts a wide net across the sector, but it captures large-scale and high-end businesses most directly and most often: luxury, bridal and watch jewellers with high average transaction values, wholesalers and suppliers, bullion and coin dealers, auction houses, estate and secondary-market dealers, and manufacturers who transact directly with clients.
If your business regularly closes five- and six-figure sales — bridal collections, investment-grade stones, bullion, estate pieces, luxury watches — you meet the DPMS threshold. FINTRAC expects a compliance program calibrated to that transaction profile and your business nuances, not a template built for a dealer who crosses $10,000 only occasionally.
WHAT REPORTING OBLIGATIONS DO DPMS HAVE?
DPMS obligations are narrower than those of banks or money services businesses, but they aren't optional, and FINTRAC has shown it will issue significant penalties for gaps. Core obligations include:
compliance programS
A documented program with a designated compliance officer, written policies and procedures, a risk assessment, ongoing staff training, and a biennial compliance effectiveness review is required. Remember, under Bill C-12, Compliance Programs must be proven effective in practice; not just a document.
client identification
This includes verifying client identity for transactions that trigger reporting or record-keeping requirements, using government-issued photo ID or an acceptable dual-process/electronic verification method.
large cash transaction reports (LCTRs)
LCTRs are filed when you receive $10,000 CAD or more in cash in a single transaction, or in two or more cash amounts totalling $10,000 or more within 24 consecutive hours from the same client — this is the "24-hour rule."
large virtual currency reports
The same $10,000 / 24-hour threshold applies where virtual currency is received.
suspicious transaction reports (STRs)
STRs are required whenever there are reasonable grounds to suspect a transaction, or attempted transaction, is related to money laundering, terrorist financing, or sanctions evasion — a lower bar than certainty, applying regardless of transaction size.
sanctions screening
Screening and reporting related to listed or sanctioned persons and entities.
record keeping
Transaction and client identification records need to be retained for at least five years, and producible to FINTRAC within 30 days of a request. All DPMS must keep their records up to date and in line with current regulatory obligations.
WHAT our compliance services cover for dpms
The AML Shop works with precious metals and stones dealers who operate at locally and at scale — multi-location retailers, wholesalers and suppliers, auction houses, and dealers whose banking and payment relationships depend on demonstrable compliance. Our services include:
aml program design and documentS
Built around your transaction profile, client base, and locations.
risk assessments
Covering products, clients, delivery channels, and geography.
policies and procedures
For client identification, large cash/virtual currency reporting, and suspicious transaction detection.
staff training tailored by role
Sales floor, wholesale/purchasing teams, management and CAMLO.
compliance effectiveness reviews
Includes Compliance Effectiveness Reviews that FINTRAC expects every two years. We also offer readiness and gap assessments.
bank and payment processor support
Advisory support helping clients respond to due diligence requests from banks and payment processors — often the more immediate pressure point for high-value dealers than a FINTRAC examination itself.
ongoing advisory
As your business grows, adds locations, or expands into new product lines such as bullion, estate, or high-value stones, we can provide continued AML advisory support.
book a consult with an aml expert
Whether you're building your first AML program or having an existing one reviewed for gaps that need advice or remediation, our consultants work with jewellers, wholesalers, and precious metals dealers across Canada to design programs that satisfy FINTRAC — and stand up to scrutiny from your bank.
Reach out using the contact form below or email the team directly. We will confirm your sector, programme scope, and timeline requirements before proposing a review approach.
Reach out to an AML Expert.
KEY CONTACTS
Marcelle Dadoun - Principal, Program Design and Advisory
marcelle@theamlshop.ca
LinkedIn
Marcelle Dadoun, Principal, Program Design and Advisory leads The AML Shop's compliance program design division and provides advisory support to all reporting types, including new and evolving money services businesses, payment service providers and fintech clients looking to navigate local and international regimes for registration, licensing, and regulations. Additionally, she has developed and currently leads the Retail Payment Activities Act (RPAA) program division at The AML Shop. Read more.
FAQS
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A DPMS is any person or business that, in the course of business, buys or sells precious metals (gold, silver, platinum, palladium) or precious stones (diamonds, sapphires, emeralds, rubies, and similar) where a transaction reaches $10,000 CAD or more. This includes jewellers, wholesalers, bullion and coin dealers, and auction houses, and it triggers reporting entity obligations under the PCMLTFA.
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No. Unlike money services businesses, DPMS are not required to formally register with FINTRAC. However, they are still reporting entities under the PCMLTFA and must maintain a compliant AML program, file required reports, and keep records — registration status doesn't change that obligation.
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The $10,000 threshold triggers a Large Cash Transaction Report (or Large Virtual Currency Transaction Report) when a dealer receives $10,000 CAD or more in cash in one transaction, or in multiple related cash payments totalling $10,000 or more within a 24-hour period from the same client. Structuring a sale to stay under this threshold is itself a red flag that can require a suspicious transaction report.
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A Suspicious Transaction Report (STR) is required whenever there are reasonable grounds to suspect a transaction, or attempted transaction, is connected to money laundering, terrorist financing, or sanctions evasion. This threshold applies regardless of the dollar amount involved, and it can apply even to a sale that's never completed.
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Client identification and transaction records must be retained for at least five years and be producible to FINTRAC within 30 days of a request. Records can be kept electronically, provided a paper copy can be produced if needed.
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Banks and payment processors face their own regulatory pressure to manage risk in the accounts they hold, and DPMS clients with high-value cash and international transactions are considered higher risk. A documented, up-to-date AML program is often the fastest way for a dealer to satisfy a bank's due diligence request and avoid account restrictions or closure.
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FINTRAC can issue administrative monetary penalties (AMPs) for non-compliance, ranging from smaller penalties for record-keeping gaps to significant fines for systemic failures in areas like client identification or reporting. Penalty decisions are increasingly made public, which adds a reputational dimension to non-compliance beyond the fine itself. You can view the public penalty list on FINTRAC’s website.
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Yes. The underlying obligations are the same, but a business with multiple locations, wholesale relationships, high-value inventory, or high transaction volume faces a proportionally higher risk profile and more reporting activity. An effective program for a business at that scale needs stronger internal controls, role-specific staff training, and a risk assessment that reflects the actual volume and value of transactions — not a template sized for a much smaller operation.
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