Guidance

Risks common to all high value dealers

Updated 14 November 2025

Money laundering

The UK National Risk Assessments give a consistent view that cash is extremely high-risk due to it being untraceable, readily exchangeable and anonymous.

The National Risk Assessment 2025 assessed high value dealers as facing a medium risk for money laundering.

High-value goods are appealing to criminals partly due to their versatility. Goods purchased with criminal cash can be re-sold, either for profit or loss in exchange for clean funds. They can also be kept as a store of value, or, depending on the goods in question used as status symbols.

The risk is heightened in cases where remote cash payments are involved, either through couriers stated to be delivering cash for customers or depositing cash directly into your bank account.

High value goods such as watches, precious stones and jewellery can also be moved across international borders, through passenger routes, without attracting the same attention as large cash movements. 

Find out how to risk assess your business for money laundering.

Terrorist financing

The National Risk Assessment 2025 assessed high value dealers as facing a low risk for terrorist financing purposes. The sector can provide opportunities to obtain small objects of high value, which:

• can be moved across borders without the need for individual export licences
• might not be checked by customs officials 

Proliferation financing

Proliferation financing means providing funds or financial services for use in the manufacture, acquisition, development, transfer and shipment of chemical, biological, radiological or nuclear weapons (also known as weapons of mass destruction) and their delivery systems. The proliferation financing measures exist to prevent the build-up of weapons of mass destruction by certain regimes.

The UK proliferation financing sanctions regime:

• highlights designated people and businesses sanctions for proliferation financing purposes
• includes specific sanctions against chemical and nuclear weapons

Current sanctioned businesses, individuals and countries include:

• Iran
• North Korea
• Russia
• Syria

It is important to check the UK sanction list, which is regularly updated.

It is possible high value dealer goods could be dual-use goods, precursor chemicals or raw materials of use in a weapons of mass destruction programme, or could be sold to fund proliferation financing.

You must also consider the risks as detailed in the national risk assessment of proliferation financing. 

Risks common to all high value dealers

The goods bought and sold by high value dealers can include higher and lower risk activities. It is important that businesses understand and review the risks presented by activity and each customer.

The key cross-sector risks for all high value dealers include:

• unusual sales or purchase activity
• linked transactions
• goods purchased by organised criminal groups
• payments into bank accounts or made by cash
• country or geographical area

Goods of use to weapons of mass destruction programmes, including being used to manufacture dual-use goods

There is a risk of goods sold by high value dealers being used to finance development of weapons of mass destruction.

The Department for Business and Trade published a list of dual-use goods. These include those of use in weapons of mass destruction programmes and finished products and raw materials.

Any business or individual involved in a transaction for, or linked to, dual-use items would be higher risk, especially those also linked to regimes sanctioned for proliferation financing. Use of unclear company structures, trusts and intermediary jurisdictions would also indicate a higher risk in such a transaction or series of transactions.

Customers linked to the governments of proliferation financing sanctioned regimes

There is a risk of proliferation financing in any transaction linked to a regime sanctioned for proliferation financing, including any sanctioned:

• individual
• entity
• government
• government owned entities
• politically exposed persons

These transactions should be treated as high risk. 

A potential sale or unusual purchase of goods

This could mean the goods, the delivery method or payment arrangements do not:

• appear consistent with the normal business practices for the type of business concerned
• have a clear business reason
• make economic sense

A business wants to conduct an ‘off the record sale’

The cash sale or purchase of goods for an ‘off the record sale’ is not likely to have:

• been recorded in that business’ records
• a proper audit trail

If offering payment this way, the business is also likely to be using cash for other purposes, such as paying workers cash in hand so they do not pay tax and National Insurance on the wages.

Goods and linked transactions

A linked transaction can occur when a customer wants to break down cash payments:

• artificially from one payment into smaller payments
• to avoid detection and not follow the requirements under the Money Laundering Regulations

For example, a customer buys 4 pallets of goods in cash for £5,000 each, making the total sale £20,000. Normal business practice would be for all 4 pallets of goods to be on one invoice. The transaction would therefore be caught by the Money Laundering Regulations, and appropriate customer due diligence measures would be required.

It would not be appropriate to issue separate invoices for each pallet of goods and claim they were separate sales. Whilst these individually would be under the high value dealers threshold, the total cash for the sale is still £20,000.

Dealing with an unregistered high value dealer

As part of your customer due diligence measures, if the business you are dealing with is in the UK, you should check whether it is registered with HMRC. If it is not, you should not continue with the high value cash payment.

You should consider submitting a Suspicious Activity Report to the National Crime Agency.

You can also report them to HMRC.

Criminals take advantage of legitimate businesses

Talking to your customers about the reason they need to pay you in cash will help to find out whether there is a legitimate reason for the sale and whether anything appears unusual.

A new customer

Some customers may have little or no trading history and no trade references. Consideration would need to be given to whether this customer is genuine or a front for a business that is possibly involved with money laundering.

The customer asks for the goods to be delivered in an unusual manner or to an address that is not their own

There may be a genuine reason for this, but it is important to ask questions to decide if the transaction should go ahead.

A Suspicious Activity Report on the National Crime Agency website should be filed if appropriate.

Customer travels far for goods available nearby

It does not make commercial sense for a customer to travel a long distance in the UK to purchase goods that are readily available near their home location.

If the goods you sell are unique and not readily available elsewhere, this would make business sense.

Using Scottish and Northern Irish banknotes in other parts of the UK

You must consider whether your customer has a cash business in Scotland or Northern Ireland that uses Scottish or Irish bank notes, or both. There have been law enforcement cases involving criminals buying drugs in England but paying in Scottish or Irish notes.

If the business only operates in England, it is unusual for them to have Scottish or Northern Irish banknotes. This could mean they are:

• bringing large amounts of cash from Scotland or Northern Ireland
• claiming that customers travel long distances to spend money at their location in Southern England

Both scenarios seem unlikely and may raise concerns.

When cash is presented, it may appear either as loose banknotes or bundled together. If a customer says they withdrew the money from their bank account, higher amounts are often in thousand pound bundles with a bank wrapper, and less likely to be rough bundles with rubber bands holding it all together.

If the customer claims the cash came from a casino win, then it should be wrapped in that casino’s slips, and further customer due diligence checks could be done with that casino for confirmation.

You should consider if you are satisfied there is enough evidence to support where the cash came from. If there is any doubt, you should:

• not continue with the transaction
• submit a Suspicious Activity Report on the National Crime Agency website

Suspicious cash transactions by customer

Observe the appearance of the cash and consider if the banknotes resemble those typically issued by a bank or if they appear as loosely bundled street cash. Record how the customer presents the cash, whether in a secure bag, a carrier bag, or a fast-food paper bag.

Criminals may use everyday bags like carrier or fast-food bags to avoid drawing attention while transporting cash.

Cash deposits from multiple branches

The money laundering risks are greater if a customer pays cash into your business bank account than if they pay the cash directly to you at your business.

Criminals have been known to deposit cash directly into a bank account which means the high value dealer does not not see the cash or the person making the deposit. This helps them keep their anonymity and allows multiple people to deposit criminal cash on behalf of one customer with little chance of getting caught.

Direct deposits into your account, or using third parties, also removes your ability to check the appearance of the cash (dirty, street cash or unexpected volumes of Scottish or Northern Irish notes).

You are responsible for anti money laundering checks on such deposits, not the bank or the third-party cash collection business.

You must be able to show what your procedures are to:

• monitor bank deposits or cash collection pickups
• be able to identify who put cash in to your business bank account or passed it to the collector
• challenge any unexpected deposits, amounts or unexpected locations

If relevant, complete a Suspicious Activity Report on the National Crime Agency website.

Deposits and their locations should match with what is known about the customer. Unusual patterns such as cash deposits made in multiple, distant locations on the same day may be inconsistent with the profile of a retail customer, sole trader, or small business.

Multiple small cash deposits into a business account from various locations

It is unusual to have a number of small amounts of cash paid into your business bank account, particularly if the branches are not located close to your customer.

Attention should be paid to the timings and frequency of these linked cash payments as they may be split up on purpose to avoid being noticed.

If a customer or representative is paying in cash, and is located near to you, normal practice would be for them to come to your premises and pay you personally rather than go to a bank and pay the cash in. It is your responsibility to carry out checks on customers making such cash payments.

Cash deposits from unknown individuals

If the person paying you the cash is not known to you or does not appear to have a link to your customer, you must find out how they got the customers money.

It is important to identify the person delivering the cash and their relationship to your customer.

Understanding where your customers’ money comes from

If your customer runs their business outside the UK, you need to check where the money came from and make sure there’s clear evidence to support the source of the cash.

If the money comes from a foreign exchange, especially in the UK, your customer should provide proof (for example, a receipt). You must retain a copy as part of your customer due diligence checks.

Customer does not have a business bank account

If a customer is using a personal bank account instead of a business account, you should consider the reason. It may be:

• to avoid business banking charges
• due to a business account being closed
• because the bank has refused to open one

Payment from high-risk jurisdictions

High-risk jurisdictions are more likely to be linked to money laundering and terrorist financing.

You should carefully consider the purpose and nature of any transaction with a business from a high-risk jurisdiction.

There are risks for high value dealers in relation to the country that their customers are operating in. Some jurisdictions are deemed higher risk than others and have poor or insufficient money laundering and terrorist financing measures.

Other risks in a jurisdiction include:

• levels of bribery and corruption
• tax evasion
• capital flight
• conflict zones
• organised crime activity

It is not only the country that the customer is based in that may be the risk, but it could also be neighbouring countries as money laundering or terrorist financing often involves the movement of funds across borders.

Information about high-risk jurisdictions is widely available, which is detailed from several open-source documents and media.

All high value dealers will need to decide their own level of comfort when assessing jurisdictional risk. The business will be expected to develop and maintain awareness around this topic and include it in their written policies and procedures and risk assessment.

Cash payments from jurisdictions with cash movement limits

Many countries have strict limits on the volume of cash that can be legally used or taken out of that country, often around 10,000 dollars or equivalent.

If your customer operates in one of these countries and exceeds that cash limit, it is likely that cash is being used to avoid local restrictions. Care should be taken to make sure cash has been properly declared at borders.

Cash payments from overseas customers without evidence of UK travel or business premises

If a customer has travelled to the UK, they should be able to provide evidence of their travel. Regular cash payments made in person should be checked against the cost of travel and whether these costs are reasonable in relation to the value of the goods provided.

Cash brought into the UK

As part of your customer due diligence checks a copy of form C9011 should be requested from any customers travelling to the UK, from outside the EU, with more than 10,000 euros in cash.

Source of cash funds

If a customer provides C9011 evidence of bringing sterling into the UK, you should still check the source of the funds. Consider whether it is reasonable for someone from that country to hold large amounts of UK sterling, or whether the funds may be linked to criminal activity.

Commercial sense of the transaction

You need to consider if the sale of goods makes commercial sense. For example:

• a business overseas is buying large quantities of goods from a UK high value dealer, but there is no marketplace in that country for these goods for re-sale
• the director travels to the UK to pay for the goods but a bank transfer would be quicker, easier and cheaper

There are higher levels of risk whenever you are involved with supply chains of goods but do not have physical sight or control of the goods, especially if you do not have a relationship with the named seller or buyer.

In some money laundering methods, third party payment invoices are either:

• made up by criminals (the invoice does not relate to any sale of goods)
• amended to change the bank account details to one that is controlled by the money launderers

The invoice is simply used to try to claim some legitimacy for the movement of the money.