Would you classify a business who purchases and sells rare coin collections as a currency dealer and therefore an MSB? Our customers account only has check transactions going to other coin dealers and auction outfits and incoming deposits are checks from the same; for what I would assume is the exchange of coins.

The customer states that these coins are for private investment.

And yes, transactions are above $1000.

Any advice would be greatly appreciated.

No, I would classify them as a coin wholesaler, or NAICS 423940

we have one here - same scenario- very large deposits as a result of the buying and selling of coins. we don't consider them and msb but I monitor their transactions every few months if time allows. when the account was first opened I did a full bsa review on the relationship.

They should be risk rated the same as a jewelry dealer, etc., or some other business dealing in small, high value goods, but based on the description not an MSB

Thank you for all you input. It helped a lot.