Personally I'd restrict ALL accounts, so if you have any general area / community chat channels, you CAN'T use them unless you have a full retail copy of the game or have paid a subscription fee / whatever the payment mechanic is. I'd apply the same mentality to whispers / tells.
So anyone using those chat mechanics has paid money. In the terms I'd state outright that peddling gold will instantly BAN you from public channels and whispers. At that stage, you have gold sellers who have paid you money for accounts and can no longer use them to peddle their wares. All good.
Flag / Notify / Report features need to be present for spammers etc. I assume these are taken care of already? Try them out in beta.