ECSH51675 - High Value Dealer services provided in other supervised sectors

Where an Art Market Participant (AMP) (as defined by regulation 14(1)(d))of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)), trades in or acts as an intermediary in the cash sale or purchase of works of art where the value of the transaction, or a series of linked transactions, amounts to 10,000 euros or more, they fall within the scope of MLR 2017 as a High Value Dealer (HVD) as well as an AMP.

This scenario is seen in only a very small number of cases.

Some auction houses will also be HVDs if they make or accept payment in cash of at least 10,000 euros in total for goods, in respect of any transaction whether the transaction is executed in a single operation or in several operations which appear to be linked.

For more information on auction houses, see ECSH54700.

Certain Dealers in Precious Metals and Stones (DPMS) may take scrap jewellery to be smelted and receive the payment in cash. If the cash payment was over 10,000 euros, or equivalent in any currency, the business would fall within the definition of an HVD.

In instances where an HVD offers other financial services, for example operating safety deposit boxes, the business will fall to be supervised by the Financial Conduct Authority (FCA) who will check to ensure compliance with MLR 2017 in respect of the HVD activity.

In all cases the business’s anti-money laundering registration must reflect all relevant activity they conduct, as must its compliance with MLR 2017.