Money laundering supervision for high value dealers
Find out if you’re a high value dealer and need to register with HMRC under the money laundering regulations.
Who should register
You may have to register with HMRC if your business operates as a high value dealer.
A high value dealer under money laundering regulations is any business or sole trader that accepts or makes high value cash payments of 10,000 euros or more (or equivalent in any currency) in exchange for goods.
Cash means notes, coins, or traveller’s cheques. This includes when a customer deposits cash directly into your bank account, or when they pay cash to a third party for your benefit.
HMRC considers a high value payment to be:
- a single cash payment of 10,000 euros or more for goods
- several cash payments for a single transaction totalling 10,000 euros or more, including a series of payments and payments on account
- cash payments totalling 10,000 euros or more which appear to have been broken down into smaller amounts so that they come below the high value payment limit
You need to register if you accept or make high value payments for the following:
- single high value cash payments for a large quantity of low value goods
- high value wholesale or retail transactions
- a single high value transaction made in instalments or on account
You must not accept or make a high value cash payment until you have registered as a high value dealer.
Dealing in goods
You’re dealing in goods if:
- you’re an agent or auctioneer who does not own the goods
- the goods do not change ownership at the time of transaction (for example, sale or return)
- the transaction involves goods and services, and you supply goods with an open market value of 10,000 euros or more (for example, fitting a kitchen or bathroom)
Who does not need to register
You do not need to register if you:
- only receive payments for services or for a mix of goods and services where the value of the goods is less than 10,000 euros
- are only ever paid large amounts by credit card, debit card or cheque
It’s good practice to have a written policy saying you will not accept high value cash payments and to make sure your staff are aware of it.
When to register
You must register with HMRC straight away if you decide that you’ll accept or make high value cash payments. You’ll be able to pay your fees at the same time.
Find out which fees you’ll pay for money laundering supervision.
Annual supervision
At the end of each registration period, HMRC will send you an annual supervision notice reminding you to update your registration and pay the annual fee on all your listed premises.
If you do not need your registration to continue, then you should tell HMRC.
If you do not pay the correct fee, then HMRC may terminate your registration and remove your business from its anti-money laundering register.
Get more information
HMRC has published guidance for high value dealers on how to comply with their obligations under the money laundering regulations and related legislation.
The guidance explains what businesses must do to protect themselves from the risks of money laundering and terrorist financing and how to report suspicious activity.
More information is available about recognising and reducing risk of money laundering if you are a high value dealer.
You can also watch recorded webinars to find out more about money laundering supervision.
Updates to this page
Last updated 10 August 2022 + show all updates
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A reference to proliferation financing has been removed, as the guidance for high value dealers does not contain this information.
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The further information section has been updated as guidance for high value dealers now includes information about proliferation financing.
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If you make or accept high value payments of €10,000 or more for goods, you need to register for anti money laundering supervision with HMRC.
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This guidance has been updated to reflect legislation changes effective from 26 June 2017.
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Content reviewed and updated to simplify the registration process.
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First published.