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HMRC internal manual

Money Laundering Regulations: Compliance

Legislation: Safe custody services

A safe custody service offers safety deposit boxes or other secure storage suitable for high value physical items like jewellery or documents of title. A business solely offering the following services would not be considered to be a safe custody service:

  • The storage of goods such as luggage, household items or motor vehicles;
  • The storage of non-physical property like computer data;
  • The secure transportation of high value items;
  • Offering safe custody on an occasional or very limited basis, such as hotels providing a safe for use by guests.

When deciding whether the exemptions applies you need to take into account all the financial activities that fall within scope of the regulations

Some MSBs may provide safe custody services but you will need to check whether they fall within scope of any the exemptions: e.g. a hotel registered as a bureau de change providing a safe for use by guests would not need to include their safe custody services within their anti money policies and procedures.

Risks: Customer may use the safe custody services to store criminal property.