Identity Verification
Also: Customer due diligence, KYC, Know Your Customer, ID check
Identity verification is the legally required customer due diligence a dealer must carry out when precious metals are bought or sold in cash above certain thresholds under Ireland's anti-money-laundering legislation.
Anyone buying or selling gold, silver or other precious metals for cash will sooner or later run into identity verification. Under Ireland's anti-money-laundering framework, dealers are obliged to establish who their customer is once a transaction crosses a defined threshold or once anything suspicious comes to light. The purpose is to stop the precious-metals trade from being used to launder money or finance terrorism.
The legal basis
The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended) treats precious-metals dealers as "designated persons" who must apply customer due diligence, of which verifying the customer's identity is a core element. For cash dealings the following applies:
| Threshold | Situation | Obligation |
|---|---|---|
| From EUR 10,000 (cash) | Purchase or buy-back of precious metals | Full identification |
| Below the threshold | Suspicion of money laundering | Identification and, if appropriate, a report to the Garda / Revenue |
| Deliberately split transactions | Combined value at or above the threshold | Identification still applies (no smurfing) |
For non-cash payments (bank transfer) the identity is usually already established through the payment channel itself, so separate arrangements apply.
Note: Thresholds and how they are interpreted can shift as the law is amended. This is not legal or tax advice.
What is checked?
The dealer records and documents the following details:
- Full name (first and last name)
- Date and place of birth
- Nationality
- Residential address
- Type and number of the identity document (passport or national ID / driving licence, per current guidance)
The records are generally copied or scanned and retained for a set period as required by the Act. A valid, government-issued photographic document is essential; a store card or medical card is not accepted for this purpose.
How it works at the dealer
A typical identity check runs like this:
- The customer wishes to buy or sell coins or bars in cash above the threshold (for instance after checking the Buying Price Calculator).
- The dealer asks for a valid passport or accepted photo ID.
- The details are recorded and the document is copied.
- The transaction is documented internally and archived in an audit-proof way.
- Only then is the deal completed.
If a customer refuses to be identified, the dealer must decline the transaction and, where warranted, file a suspicious transaction report.
Over-the-counter cash and anonymity
The classic anonymous over-the-counter cash transaction is only possible below the statutory threshold. Above it there is no lawful way to acquire or dispose of precious metals anonymously for cash, whether the deal takes place with a dealer, a bank or a pawnbroker. Where multiple transactions are plainly being split up to stay under the cash limit, the dealer must still verify identity and report the matter.
Connection with tax liability
Identity verification has no direct bearing on how a gain from selling precious metals is taxed. In Ireland, a private individual's gain on bullion falls under Capital Gains Tax at 33%, after the annual personal exemption of EUR 1,270, with no holding-period relief. (By contrast, Germany applies a one-year speculative period under Paragraph 23 of its income tax act.) The AML documentation simply adds transparency toward the authorities. This is not tax advice — consult a qualified adviser if in doubt.
In brief
Identity verification is a statutory tool for combating money laundering in the precious-metals trade, and it affects every buyer or seller carrying out cash transactions above the Irish AML threshold. Anyone buying or selling gold at or above the limit should always carry a valid photographic identity document.