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 ML Regs : High Value Dealer Registration

By HMRC

Overview

You’re classed as a High Value Dealer if your business accepts cash payments of €15,000 or more (or equivalent in any currency) in exchange for goods. You’ll need to register with HM Revenue and Customs (HMRC) for supervision under the Money Laundering Regulations 2007.

This guide will help you decide if you need to register as a High Value Dealer and includes links to information on how to register.

High Value Dealers

The term High Value Dealer has a special meaning under The Money Laundering Regulations 2007. The Regulations describe a High Value Dealer as any firm or sole trader that receives high value payments of €15,000 or more in cash in exchange for goods.

A high value payment is a payment in any currency equivalent to €15,000 which is made either in a single transaction or in several instalments which are linked. Cash payments made to you in person or directly into a bank account are high value payments if they meet these criteria.

HMRC classes as High Value Payments as:

  • a single cash payment of €15,000 or more
  • several cash payments totalling €15,000 or more, including a series of payments and payments on account
  • cash paid by a customer totalling €15,000 or more in any 90 day period
  • cash payments totalling €15,000 or more which appear to have been broken down into smaller amounts to come below the High Value Payment limit

Examples of High Value Dealers

Certain types of business are particularly likely to be High Value Dealers, such as:

  • motor dealers
  • jewellers
  • antique and fine art dealers
  • boat dealers
  • builders, bathroom and kitchen suppliers
  • auctioneers and brokers

Businesses such as auctioneers and yacht 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.

When you don’t need to register as a High Value Dealer

Not all businesses that receive payments worth €15,000 or more need to register with HMRC as High Value Dealers. You won’t 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 perhaps because you’re only ever paid large amounts by credit card, debit card or cheque

It’s good practice to have a written policy and to make sure your staff are aware of your policy on high value cash payments if you don’t intend to accept them.

Registering with HMRC as a High Value Dealer

You should register with HMRC straight away if you decide that you’ll accept high value cash payments. You mustn’t accept a high value cash payment until you have registered as a High Value Dealer.

Published June 2015