HMNCT2040 - Background: Why has HMRC introduced this requirement when legislation is currently in force covering cash transactions within the Money Laundering Regulations (MLR) 2003?

Under the requirement introduced by the Alcohol Strategy, all affected traders (see HMNCT3010) are required to notify HMRC of all cash transactions specifically involving the sale of duty suspended alcohol or the provision of alcohol related services where the full amount of cash received or (for part payments) expected for the sale or service exceeds £9,000 (see HMNCT3040 for instalment payments). The requirement is targeted at identifying high risk transactions in relation to duty suspended alcohol rather than money laundering.

HMRC has adopted the key definitions and financial limits within this measure from the MLR to ensure consistency. However the two schemes have separate objectives and are covered by separate legislation.

The requirement for traders to notify HMRC of all cash transactions for sales or services provided in relation to alcohol has been introduced under section 118B(1) of the Customs and Excise Management Act (CEMA) 1979.

Although the two schemes are different, information obtained from cash transactions will also help HMRC to assure compliance within Money Service Business (MSB) obligations.

Original notification to the trade of this requirement can be found in Excise Information Sheet 03/05