Find out if you’re a high value dealer and need to register with HM Revenue and Customs (HMRC) under Money Laundering Regulations.
Who should register
You may have to register with HM Revenue and Customs (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 or more (or equivalent in any currency) in exchange for goods. 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 or more for goods
- several cash payments for a single transaction totalling €10,000 or more, including a series of payments and payments on account
- cash payments totalling €10,000 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 are dealing in goods if:
- you are an agent or auctioneer who doesn’t own the goods
- the goods don’t change ownership at the time of transaction (for example, sale or return)
- the transaction involves goods and service and you supply goods with an open market value of €10,000 or more (for example, fitting a kitchen or bathroom)
Who doesn’t need to register
You don’t 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
- are only ever paid large amounts by credit card, debit card or cheque
It’s good practice to have a written policy saying you won’t accept high value cash payments and to make sure your staff are aware of it.
When to register
At the end of each registration period HMRC will send you a renewal notice reminding you to pay the annual fee on all your listed premises. If you don’t need your registration to continue then you should tell HMRC.
If you don’t pay the correct renewal fee then HMRC may terminate your registration and remove your business from its anti-money laundering register.