Money laundering does not only run through banks. High-value goods — luxury cars, fine jewellery, art, gold, watches — are an attractive way to convert dirty cash into assets that hold value and can be moved or resold. That is why dealers in such goods are pulled into the AML regime once they accept large cash payments. If you buy or sell high-value items for significant cash, you may be a "high-value dealer" with real obligations.
Who counts as a high-value dealer
The trigger is cash. A business becomes a high-value dealer when it accepts (or makes) cash payments of €10,000 or more for goods — whether in a single transaction or several linked ones.
| Sector | Example businesses |
|---|---|
| Vehicles | Car, boat and aircraft dealers |
| Luxury | Jewellers, watch dealers, designer goods |
| Precious metals | Gold and bullion dealers |
| Art & antiques | Galleries, dealers, auction houses (also "art market participants") |
| Other | Any dealer accepting €10,000+ in cash for goods |
What you must do
- Register with HMRCRegister for AML supervision before accepting qualifying cash payments.
- Apply CDDIdentify and verify customers on qualifying transactions.
- Screen for sanctionsCheck customers against UK and international sanctions lists.
- Keep recordsRetain CDD and transaction records (generally five years).
- Train staffEnsure staff can recognise and handle ML risk.
- Report suspicionFile SARs with the NCA where you suspect laundering.
Test your understanding
Decide whether each situation brings the high-value-dealer cash rules into play.
A customer pays €12,000 in cash for a single watch.
Why criminals like high-value goods
A suitcase of cash is conspicuous and hard to spend. Converted into a watch, a gold bar or a car, the same value becomes portable, storable and resaleable — a way to launder and to hold wealth. That is why the regime targets the cash entry point, and why structuring (splitting payments to dodge the threshold) is itself a warning sign.
Where Probitas fits
When a customer makes a large purchase, you need to know who they are and whether they carry sanctions or other risk. A Probitas check screens individuals and companies against sanctions, PEP and adverse media sources and surfaces the public record, anchored to its origin — supporting the CDD and sanctions screening high-value dealers must perform. Registration and reporting remain your own responsibility.
High-value
What is a high-value dealer?
A business that accepts (or makes) cash payments of €10,000 or more for goods, in a single transaction or several linked ones. At that point it falls within the AML regime and must register with HMRC for supervision.
Does the rule apply if I only take card or bank payments?
The high-value-dealer registration trigger is about large CASH payments. If you do not accept cash of €10,000 or more for goods, the specific high-value-dealer cash rules may not apply — though general AML awareness and sanctions obligations still do.
What obligations do high-value dealers have?
Registering with HMRC, applying customer due diligence on qualifying transactions, screening customers against sanctions lists, keeping records (generally five years), training staff, and reporting suspicion via SARs to the NCA.
Can someone avoid the rules by splitting a cash payment?
No. Linked transactions are aggregated, so splitting a purchase into smaller cash payments to stay under €10,000 (structuring) does not avoid the rules — and is itself a red flag.
Do sanctions rules apply to high-value sales?
Yes. Businesses involved in high-value transactions are expected to screen customers against UK and international sanctions lists. Sanctions prohibitions apply regardless of the cash threshold — a designated person cannot lawfully buy a high-value asset from you.
Sources
This guide is written from primary sources. Each is linked below; claims in the text link to the specific reference they rely on.