High value dealers

It has been around a year since new regulations aimed at preventing money laundering became effective. As businesses dealing in goods (not services) that accept large cash payments are affected by certain measures introduced under the new regulations, now is a good time to remind yourself of the main requirements.

The high value dealer (HVD) rules are part of a range of measures introduced by the government to reduce criminal activity and ultimately deter money laundering. While the HVD rules are most likely to affect those businesses that deal in high value or luxury goods such as cars, jewellery, works of art, etc., potentially any business that deals in goods (not services) and accepts payment in cash equivalent to €15,000 (around £10,000) for any single transaction may be affected. For example, a wholesale business may find that a customer unexpectedly wants to pay in cash on one occasion. Alternatively, a business may find that a customer wants to pay cash for a second hand asset.

Where an unregistered business selling goods finds itself in a situation where a large cash payment is offered, it essentially has the following choices:

• refuse the transaction
• request payment by another method or
• register the business immediately with Customs and Excise, before accepting the cash payment.

HVD businesses must adopt anti-money laundering policies and procedures. These can be summarised into the acronym CATCH:

Control your business by having anti-money laundering systems in place
Appoint a Nominated Officer
Train your staff
Confirm the identity of your customers
Hold all records for at least five years.

If you think your business may be affected by the rules and would like to find out more we would be pleased to discuss the requirements with you.