Gold and silver coins sit at the junction of several AML/CTF categories: bullion, precious products, physical currency and collectibles. A legal-tender coin can be a currency-like item, an investment product and a collector's object at the same time. The correct classification determines the threshold, the CDD requirements and the reporting obligations. This guide explains how dealers should approach the classification and the evidence the file needs. Because the definitions are technical and product-specific, dealers should confirm the current Act, Rules and AUSTRAC guidance for each coin line.
Start with the product, not the label
A coin's treatment depends on what it is and how it is sold: a bullion coin sold for its metal value, a legal-tender coin sold at face value, a collectible sold for numismatic value. The same physical coin can be classified differently in different transactions. The dealer should record the classification per transaction line and the basis for it.
Legal tender is a legal characteristic, not a compliance short-cut. A coin being legal tender does not by itself decide whether a sale is bullion, a precious product or a currency transaction under the AML/CTF framework.
Bullion versus precious items
A dealer selling both bullion bars and collectible coins may operate under both frameworks. The file should show which item applies to each line and how the threshold test was applied.
- Bullion dealing has been regulated since Tranche 1 and carries its own obligations
- Non-bullion precious metals, stones and products use the physical-currency or virtual-asset threshold
- The product's form, content and marketing determine which item applies
- Record the analysis so the threshold and CDD decisions are traceable
CDD and threshold testing
Threshold testing is a before-the-deal control. A dealer that classifies after payment cannot demonstrate compliance. The point-of-sale record should capture the item, value, payment method and customer decision together.
- Test the transaction value and payment method before the deal
- Apply the applicable threshold to the classified item
- Complete customer identification where the item is captured
- Screen for PEPs, sanctions and adverse media
- Record the customer link so repeat purchases are visible
Reporting and records
Coin dealers see the same customer returning with different products and payment methods. The transaction records should make those patterns visible, so the dealer can assess them rather than treat every sale as an island.
- Lodge TTRs for individual physical-currency transactions at or above A$10,000
- Monitor linked purchases across the coin lines
- Lodge SMRs where the pattern creates reasonable suspicion
- Retain the classification, CDD, transaction and screening records
Official sources
Confirm the current rules against these primary sources.
Questions
Is a legal-tender gold coin physical currency for TTR purposes?
The classification depends on the coin, the transaction and the current definitions. Physical currency means notes and coins under the Act, but the product's treatment as bullion, precious product or collectible must be assessed for the AML/CTF item.
Are bullion coins captured under bullion or precious-items rules?
It depends on the product and how it is sold. Bullion dealing is separately regulated; non-bullion precious items use the threshold test. Record the classification per line.
Do we need CDD for every coin sale?
Where the classified transaction is a designated service, applicable customer identification must be completed before the transaction. The threshold test determines the application.
What records should a coin dealer keep?
The product classification, threshold test, customer identification, screening, transaction value and payment method, and any reporting decisions, retained for the required period.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
- Dealer checklist3 min
A transaction-level AML/CTF checklist for Australian precious-metals, stones and products dealers: thresholds, CDD, linked transactions and reporting.
- Bullion dealer operations6 min
A day-to-day Australian bullion compliance guide covering designated services, the sub-A$5,000 initial-CDD exemption, monitoring, TTRs, SMRs and evidence.
- TTRs explained3 min
Threshold transaction reports for Australian practices and dealers: what counts as physical currency, the A$10,000 threshold, aggregation traps, the 10-business-day deadline, and how TTRs differ from SMRs.