You are a High Value Dealer if you deal in goods and accept (or you are prepared to accept) a cash payment of at least 15,000 euros in total, whether this is single transaction or several transactions that are or appear to be linked. High Value Dealers must be registered with HM Revenue and Customs (HMRC). As a registered High Value Dealer you must comply with the Money Laundering Regulations 2007. For further general information on the Money Laundering Regulations 2007 please click here.
To satisfy the requirement for full compliance with the regulations you must have in place a comprehensive anti money laundering culture within your business. This entails having published anti money laundering systems, policies, procedures and carrying out checks into all customers. Also all senior management and relevant staff must be trained and you must have evidence of training. For further details of the obligations placed upon by the Money Laundering Regulations 2007 please click here.
Under the Money Laundering Regulations 2007 High Value Dealers will be regulated by HMRC and will be visited by Money Laundering Officers (“MLO’s”). The MLO’s role will be to ensure compliance with Regulations and to enforce compliance by means of UNLIMITED PENALTIES AND/OR INSTITUTING CRIMINAL INVESTIGATIONS.
Although the requirements may sound onerous, through adopting the risk based approach, your business should only incur costs in terms of both of time and financially that are proportionate to the risk, focusing effort where it is needed and has most impact. For assistance with all elements of compliance and checks required into customers please click here or contact us on 0844 561 6852 or via email.
