If your business accepts cash payments of €15,000 or more (or the equivalent in any currency) in exchange for any goods then you will be classed as a ‘High Value Dealer’ and you will need to register with HM Revenue and Customs (HMRC) for supervision under the Money Laundering Regulations 2007.
Cash payments made to you in person or directly into a bank account are high value payments if they meet the following criteria:
• a single cash payment of €15,000 or more;
• a series of cash payments totaling €15,000 or more;
• cash paid by a customer totaling €15,000 or more in any 90 day period;
• payments totaling €15,000 or more which appear to have been broken down into smaller amounts to come below the High Value Payment limit
Businesses such as auctioneers and brokers may not ever own the goods they sell, but if they receive high value cash payments for them then they are High Value Dealers.
Not all businesses that receive payments worth €15,000 or more need to register as High Value Dealers.
You do not need to register if:
• you only receive high value payments for services or for a mix of goods and services where the value of the goods is less than €15,000;
• you never receive cash payments worth €15,000 or more since you are only ever paid large amounts by credit card, debit card, cheque or bank transfer.
It is good practice to have a written policy on the acceptance of high value cash payments and to make sure your staff are informed of the policy.
You should register with HMRC if you decide to accept high value cash payments. You must not accept a high value cash payment until you have registered as a High Value Dealer.