Money Laundering Supervision For High-Value Dealers

What Exactly is a High-Value Dealer?

According to the Money Laundering Regulations 2007, the phrase "High-Value Dealer" has a specific meaning. The Regulations define a High-Value Dealer as any business or sole trader that accepts high-value sums of €15,000 or more in cash in return for products.


A large value payment is defined as payment in any currency equal to €15,000 made in a single trade or in multiple installments that are connected. If you fulfill the following conditions, cash payments made to you in person or directly into a bank account are high-value payments.


The following is a list of all the situations that HMRC classifies as High-Value Payments:


  • a single cash payment of at least 15,000 Euros
  • multiple cash payments totaling at least 15,000 Euros, including a sequence of payments and account payments
  • A customer's cash payments totaling 15,000 Euros or more in any 90-day period
  • Cash payments totaling 15,000 Euros or more that appear to have been divided into smaller sums in order to stay within the High-Value Payment limit


Exemplifications of High-Value Dealers

Certain sorts of businesses are more likely to be High-Value Dealers than others. Examples include:


  • Vehicles for transportation
  • Boats
  • Gemstones
  • Watches
  • High-priced metals such as gold, silver, or platinum
  • Diamonds, sapphires, and other valuable stones
  • Works of art
  • Printed materials
  • Safeguarded foreign items
  • Sculptures;
  • Photographic materials
  • Sculpture in any medium
  • Other works of art or cultural artworks.


Auctioneers and yacht dealers, for example, may never own the things they sell. However, if they get high-value cash transactions for them, they are considered High-Value Dealers. When is it not Necessary to Register as a High-Value Dealer?

Not all firms that receive payments of €15,000 or more are required to register as High-Value Dealers with HMRC. You will not be required to register if and only if the following conditions are met:


What is Criminal Property?

Criminal property is the proceeds of criminal activity. No matter where it occurs, this covers any act that would be considered a criminal offense if performed in the United Kingdom. It covers not just drug trafficking, tax evasion, fraud, forgery, and theft but also any other criminal offense has done for monetary gain.


It is also critical to note that money laundering covers the proceeds of any crime, not only the more often connected crimes such as drug trafficking and prostitution.


Under the law, there are three major money laundering offenses that encompass criminal behavior, as well as two related money laundering offenses:


  • hiding, disguising, converting, transferring, or removing illegal property 
  • arranging for the purchase, retention, use, or control of illegal property by or on behalf of another person
  • obtaining, employing, or holding illicit property
  • incompetent to disclose knowing or doubting, or having reasonable grounds to believe, that another person is involved in money laundering or terrorist financing


Disclosing that a disclosure of suspicion of money laundering has been made, or that an inquiry into money laundering offenses is being conducted, or is being considered when this is likely to prejudice an investigation. This is referred to as 'tipping off.'


HVDs must be aware of how these acts may influence their business, such as when criminal funds are spent (or laundered) within their company. Anyone implicated in money laundering faces harsh penalties under the law. The Regulations require HVDs to implement anti-money laundering measures in order to protect themselves against money launderers' misuse and the danger of penalties.


What Anti-money Laundering Rules and Procedures Must be in Place?

Your company should create, evaluate, and maintain policies and processes for:


  • risk evaluation and management


If you would like to stick to the local and global anti-money laundering regulations and recommendations, you can contact us and request a demo for further details on our AML solutions of Sanction Scanner.

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