HMRC has updated its guidance for high value dealers and other businesses it authorises.
HMRC has updated its guidance for high value dealers and other businesses it authorises, highlighting that customer due diligence checks must be carried out before making or receiving payments in the course of business transactions. Generally a High Value Dealer is any business or sole trader that accepts or makes high value cash payments of €10,000 or more (or equivalent in any currency) in exchange for goods. This includes when a customer deposits cash directly into your bank account, or when they pay cash to a third party for your benefit.
These checks must include verification that UK customers/suppliers are registered with HMRC as high-value dealers (paragraph 4.8).
In 4.8 the sanction for non-compliance is clear; it is highlighted that if ‘they are not registered as a high value dealer you should not continue with that high value cash payment. You should consider reporting this activity to the National Crime Agency NCA) via a Suspicious Activity Report (SAR). Failure to do this may result in sanctions being applied to your business, including the possibility of withdrawing your HVD status and your details being published on GOV.UK.’
Obviously, those advising these businesses need to consider these rules.