High Value Dealers and Money Laundering Regulations

Any business which accepts cash payments of ay least € 15,000 (or equivalent in any currency) in exchange for goods is a High Value Dealer and must register with HM Revenue & Customs (HMRC) for supervision under the Money Laundering Regulations 2007.

This guide will help you decide if you need to register as a High Value Dealer and includes links to information on how to register.

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What is a High Value Dealer?

The term High Value Dealer has a special meaning under The Money Laundering Regulations 2007. The Regulations describe a High Value Dealer as any firm or sole trader that receives high value payments of €15,000 or more in cash in exchange for goods.

A high value payment is a payment in any currency equivalent to €15,000 which is made either in a single transaction or in several installments which are linked. Cash payments made to you in person or directly into a bank account are high value payments if they meet the above criteria.

Below is a summary of all the circumstance that HMRC class as High Value Payments:

  • a single cash payment of 15,000 Euros or more
  • several cash payments totalling 15,000 Euros or more, including a series of payments and payments on account
  • cash paid by a customer totalling 15,000 Euros or more in any 90 day period
  • cash payments totalling 15,000 Euros or more which appear to have been broken down into smaller amounts to come below the High Value Payment limit

Examples of High Value Dealers

Certain types of business are particularly likely to be High Value Dealers examples include:

  • motor dealers
  • jewelers
  • antique and fine art dealers
  • boat dealers
  • builders, bathroom and kitchen suppliers
  • auctioneers and brokers

Businesses such as auctioneers and yacht brokers may not ever own the goods they sell. But if they receive high value cash payments for them then they are High Value Dealers.

When you don't need to register as a High Value Dealer

Not all businesses that receive payments worth €15,000 or more need to register with HMRC as High Value Dealers. You won't need to register if:

  • you only receive high value payments for services or for a mix of goods and services where the value of the goods is less than €15,000
  • you never receive cash payments worth €15,000 or more perhaps because you are only ever paid large amounts by credit card, debit card or cheque

If you don't intend to accept high value cash payments then it is good practice l to have a written policy and to make sure your staff are aware of your policy on high value payments.

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Registering with HMRC as a High Value Dealer

If you decide that you will accept high value cash payments you should register with HMRC straight away. You must not accept a high value cash payment until you have registered as a High Value Dealer.

To register you'll need to fill in a registration form and provide all the information requested. You can find out more about how to do this by following the link below.

How to register under Money Laundering Regulations

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