Cash Limit for Gold Purchases
Also: identification threshold, AML threshold, cash-transaction limit, due-diligence trigger
The cash limit for gold purchases sets the amount from which dealers must establish and record the buyer's identity under Ireland's anti-money-laundering rules.
Anyone buying gold with cash runs, above a certain amount, into a legal duty that surprises many purchasers: the dealer is obliged to verify the customer's identity and record it. This so-called cash limit is not a purchase ceiling but a due-diligence obligation under Ireland's anti-money-laundering framework.
Legal basis: the 2010 Act
Ireland's core statute is the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, which transposes the EU anti-money-laundering directives into Irish law. Dealers in precious metals — commercial buyers and sellers of gold, silver, platinum and palladium — count as "designated persons" once they trade in cash at scale, and must apply customer due diligence when a cash transaction reaches the statutory threshold.
For high-value dealers the trigger is a cash payment of EUR 10,000 or more, whether made in a single transaction or in several operations that appear to be linked. Where transactions are deliberately split to stay under the limit, they are treated as a single dealing.
What happens at EUR 10,000?
At and above the threshold, the dealer must establish and verify the identity of the buyer. In practice this means:
- Present photo ID: passport or national identity card (for non-nationals, potentially with a residence permit).
- Record the data: name, date of birth, address, and the type and number of the identity document.
- Retain the records: the dealer must keep them for at least five years.
- Suspicious-transaction report: on any indication of money laundering, the dealer must file a report with the Financial Intelligence Unit (An Garda Síochána).
| Cash purchase amount | Dealer obligation |
|---|---|
| Below EUR 10,000 | No mandatory identification (as a rule) |
| From EUR 10,000 | Identification + documentation compulsory |
| From EUR 10,000 (split, clearly linked) | Identification still required (no structuring) |
| Any time on suspicion | Report to the FIU regardless of amount |
Note: the EUR 10,000 threshold applies to cash. For bank transfer or debit/credit card, other due-diligence steps apply; identity is typically already evidenced through the payment channel.
Over-the-counter cash dealings below the threshold
An over-the-counter cash transaction is a face-to-face dealing settled in cash without a bank connection. Below EUR 10,000 such a purchase can, in principle, be conducted at a reputable dealer without formal identification.
In practice, many large precious-metal dealers and banks set their internal identification threshold lower, or require ID from the first euro, to minimise compliance risk. Buyers should therefore check the individual dealer's policy in advance.
What is "structuring" and why is it prohibited?
Splitting a EUR 15,000 purchase into two tranches, each just under EUR 10,000, to stay beneath the limit, amounts to an act of structuring (also known as smurfing). The law prohibits this expressly: clearly connected part-purchases are added together. Dealers who notice such patterns and still fail to carry out identification face enforcement action and penalties.
Formula: threshold check
Total value of transaction(s) ≥ EUR 10,000
→ customer due diligence applies
Purchase A (EUR 6,000) + purchase B (EUR 5,000) = EUR 11,000
→ if clearly linked: due diligence applies
Tax aspects: no link to the holding period
The cash limit is an anti-money-laundering rule and has no direct bearing on the tax treatment of a gold purchase. When a private individual in Ireland later sells physical gold at a profit, that gain is chargeable to Capital Gains Tax at 33 %, after the annual personal exemption of EUR 1,270. Ireland grants no holding-period relief — unlike Germany, where a gain becomes tax-free after one year under Paragraph 23 EStG. The tax position is unaffected by whether or not identification took place.
For an estimate of your individual gain, the tax estimator can help, alongside advice from a qualified adviser. This glossary entry is not tax or legal advice.
Obligations for buyers: what private individuals should know
Buyers have no AML obligation of their own, but must present ID at the dealer's legitimate request. If they refuse identification, the dealer may decline the transaction. The stored data are subject to data-protection law (GDPR); the dealer may not use them for any other purpose.
For the purchase of physical investment gold — VAT-exempt gold bars and certain coins — identification changes nothing legally about the purchase price. With the buying-price calculator you can work out in advance what a dealer would pay for scrap gold.
In brief
From a cash amount of EUR 10,000, precious-metal dealers in Ireland are legally required to verify the buyer's identity and keep the records for at least five years — knowing this means no surprises on your next gold purchase. The limit is not a tax rule; it serves money-laundering prevention.