High Value Dealers and AML: Cash Thresholds, Registration and Red Flags

Any business that sells goods can become a high value dealer without meaning to. A single large cash payment is enough. HMRC supervises high value dealers under the Money Laundering Regulations 2017, and in July 2026 it published refreshed guidance and a sector risk assessment for them. This guide explains what counts as a high value dealer, how the cash threshold and linked transactions work, what customer due diligence is required, and which red flags HMRC highlights. It is written for business owners, finance teams and the accountants who advise them. HMRC pages are updated regularly, so check the current version before relying on any detail.

What is a high value dealer?

According to HMRC's guidance for high value dealers, published on 8 July 2026, a high value dealer is a business that trades in goods and receives or makes cash payments of at least £10,000 in total for a transaction, whether in one operation or several linked ones. The older registration page on GOV.UK describes the threshold as 10,000 euros or the equivalent in any currency, which reflects the wording before the 2026 amendments replaced euro figures with sterling, so use the sterling figure in the current HMRC manual.

Three details trip businesses up:

• It is about cash, not card or bank transfer. HMRC says cash means notes, coins or travellers' cheques in any currency. A customer depositing cash directly into your bank account, or paying cash to a third party for your benefit, also counts.
• It is about goods, not services. Payments for services are not high value dealer activity. HMRC's example is that fixtures costing £12,000 paid in cash are in scope, while £9,000 of goods are not, even if paid in cash. Land, buildings and gift cards are not goods.
• It applies to one-off sales. You do not need to deal in expensive goods as your main business. HMRC's list of examples includes alcohol, cars, caravans and motorhomes, electronics, food, jewellery, clothing and works of art.

Art sold for £10,000 or more in cash can make a business both a high value dealer and an art market participant. Our guide to art market participants and AML covers that overlap.

Linked transactions and splitting payments

Several cash payments against a single invoice are treated as linked, however long they take. HMRC gives the example of monthly instalments on a car sold for £10,000 or more. Deliberately splitting a sale to stay below the threshold is also caught: two pallets at £5,000 on separate invoices still add up to £10,000. This is why a written policy matters. The GOV.UK registration page recommends keeping a written policy against accepting high value cash payments and making sure staff know it.

Registration

A business must not accept or make a high value cash payment until it has registered with HMRC. HMRC's manual says you must not trade as a high value dealer until you have applied to register, although you may carry on trading while the application is determined. If an unregistered business unexpectedly receives a cash sale above the threshold, it must register immediately afterwards and carry out customer due diligence before completing the sale. Businesses that only ever receive large payments by card, bank transfer or cheque do not need to register. HMRC sends an annual notice inviting registered businesses to renew and pay the annual fee for all listed premises, and may remove a business from the register if the correct fee is not paid. The registration page does not set out amounts, so check HMRC's fees page.

Customer due diligence

HMRC says customer due diligence is triggered by:

• Establishing a business relationship.
• Concluding an occasional transaction of £10,000 or more in cash, single or linked.
• Receiving cash for payments on account or accumulated debts.
• Suspecting money laundering or terrorist financing, whatever the value.
• Doubting the reliability or adequacy of customer information obtained earlier.

The customer is anyone paying or receiving a relevant cash payment of £10,000 or more, which can include cash couriers and intermediaries. Source of funds and source of wealth checks are required for politically exposed persons and for customers from countries on the FATF call for action list, including their beneficial owners. Records, including invoices, bank statements, delivery notes and the reasoning behind source of funds decisions, must be kept so transactions can be reconstructed. HMRC also reminds dealers that the Proceeds of Crime Act and the Terrorism Act apply even below the threshold, and that the Russia sanctions rules have no value threshold for covered goods.

Sanctions reporting

Since 14 May 2025, HMRC says high value dealers must report to the Office of Financial Sanctions Implementation as soon as practicable if they know or suspect that a designated person or a sanctions breach is involved. Our guide to sanctions screening explains the basics.

What HMRC says about the risk

HMRC's sector risk assessment for high value dealers, published on 8 July 2026, draws on the 2025 National Risk Assessment. It says high value dealers face a medium risk of money laundering and a low risk of terrorist financing, describes cash as an extremely high-risk payment method because it is untraceable and anonymous, and says proliferation financing should be regarded as high risk, particularly for dual-use goods with links to countries such as North Korea and Iran. The risks it highlights include cash delivered by couriers, intermediaries or direct deposits, "off the record" sales, unregistered dealers, linked transactions to avoid thresholds, complex corporate structures and sales to or from sanctioned or high-risk jurisdictions. Watches, precious stones and jewellery are named as typical high-value portable goods.

Red flags in the HMRC assessment

• Cash from couriers, third parties or unknown depositors, or customers paying cash when others do not without a clear reason.
• Requests for off the record sales or cash-in-hand arrangements.
• Payments split into smaller amounts.
• Cash inconsistent with the stated source, such as unusual bundling or worn notes.
• Unusual delivery arrangements, or delivery to a third-party address.
• Sales that lack commercial sense, such as cash used where a transfer would be easier.
• Deposits in multiple distant locations on the same day.
• Complex structures or multiple jurisdictions without a clear purpose.

HMRC also notes that using a third-party identity or compliance provider does not remove the dealer's own responsibility.

What accountants should do

If a client sells vehicles, jewellery, antiques, building supplies or similar goods, ask whether it ever accepts large cash payments and whether it has a written policy. If it does, check that it is registered, that staff recognise linked payments and that its risk assessment is up to date. Our guide to the firm-wide AML risk assessment shows how to build one. Training for the client's staff is often the cheapest control available.

Frequently asked questions

Is a business a high value dealer if it takes cash for services?

No. HMRC says payments for services are not high value dealer activity, only cash payments for goods.

Do I need to register if I only accept cards and bank transfers?

No. Businesses that only ever receive large payments by card, bank transfer or cheque do not need to register.

Do instalments count towards the threshold?

Yes. Several cash payments against one invoice are treated as linked.

Where can I get AML training for my team?

See Learnsignal's CPD courses for finance professionals.