To answer my own question:

http://www.reddit.com/r/Bitcoin/comments/1kpthd/aus_austracs... http://matholroyd.com/post/34232285907/the-irony-of-australi...

"Digital currencies potentially allow individuals and entities to conduct quick and complex international funds transfers outside the regulatory requirements of the traditional financial system. Digital currencies that are not backed, either directly or indirectly, by precious metal or bullion are not regulated by the AML/CTF Act."[0]

It's quite surprising that the law is written that way, but CoinJar is pretty proactive to positively shape the Bitcoin economy and establish legitimacy before regulation comes in. At CoinJar we have already merged the AML/CTF 100-point check into our ID verification for fraud prevention. Currently cash deposits are not regulated but bank branches have the right to require depositors to show ID.

[0] http://www.austrac.gov.au/files/typ_rprt12_full.pdf

IANAL but applying your implied criteria it seems that every online store should hold AFSL because they take money from consumers. A "financial product" has been clearly defined in CA.