MLR3C10205 - High Value Dealers: Introduction

High value dealers (HVDs) were brought within the scope of the Money Laundering Regulations 2003 with effect from 1 April 2004. They remain within the scope of the newer Money Laundering Regulations 2017. While it might be thought that HVDs registered as long ago as 2004 might have a good understanding and working knowledge of the Regulations, many of them do not appreciate the emphasis on the risk based approach. Consequently it is often the case that HVDs have not applied any meaningful customer due diligence checks in relation to long-standing customers.