You must register with HMRC as a high value dealer if your business accepts or makes cash payments of £10,000 or more in exchange for goods - in a single transaction or in linked payments that add up to it. Registration has to be in place before you accept that money, not after. The threshold moved from €10,000 to a flat £10,000 in sterling on 30 June 2026 under the Money Laundering and Terrorist Financing (Amendment) Regulations 2026.

If you never take cash above that level, you do not register. Card, bank transfer and cheque payments do not count towards it at all.

What counts as cash

HMRC's definition is narrower than people assume, and wider in one important respect.

Cash means notes, coins and travellers' cheques, in any currency. It does not include debit or credit card payments, bank transfers, or cheques other than travellers' cheques.

The wider bit: it is still cash if the customer never hands it to you. HMRC's guidance on high value dealer registration makes clear this includes "when a customer deposits cash directly into your bank account, or when they pay cash to a third party for your benefit". A customer walking into your bank and paying £12,000 in notes over the counter into your account is a £12,000 cash payment to you. Routing it through a third party does not change that either.

Linked transactions

This is where dealers get caught, and it is nearly always accidental rather than deliberate.

HMRC treats as linked:

  • several cash payments for a single transaction that total £10,000 or more
  • cash payments totalling £10,000 or more that appear to have been broken down into smaller amounts

HMRC's own Economic Crime Supervision Handbook gives the obvious example: raising four £5,000 invoices instead of one £20,000 invoice does not avoid the regime. Nor does timing - multiple payments against a single sale are linked regardless of the gap between them.

A customer paying £4,200 on Monday, £2,350 the following week and £2,850 a fortnight later against the same ring has paid you £9,400 in cash, not three unremarkable payments. The next instalment puts you over.

The practical consequence: you need a running total per customer, not a per-transaction check at the till. Most dealers who breach the threshold do so because nobody was adding up.

What registration involves

Registration is with HMRC, which supervises high value dealers under the Money Laundering Regulations 2017.

Fees, as published on GOV.UK and applying from 1 December 2025:

Item Fee
Application fee (one-off, non-refundable) £300
Premises registration fee, per premises £400
Annual declaration fee, per premises £400
Approval check, per person tested (HVDs) £40
Adding premises in the second half of the year £200

Businesses with turnover below £5,000 can claim a small business reduction - a £500 refund on approval, after paying the full amount up front. Check the current fees page before you budget; HMRC revises these.

You must be verified through a pre-registration check before conducting relevant business. Registering after you have already banked the cash is not a fix.

What you actually have to do once registered

Registration is the easy part. The obligations behind it are the work:

  • A written risk assessment of your business's exposure to money laundering and terrorist financing, kept up to date
  • Policies, controls and procedures proportionate to that risk
  • Customer due diligence - identify and verify the customer, and understand the source of funds, for qualifying transactions
  • Enhanced due diligence where the risk is higher: unusual transactions, customers from higher-risk jurisdictions, politically exposed persons
  • A nominated officer to receive internal reports and, where appropriate, submit Suspicious Activity Reports to the NCA
  • Staff training, recorded
  • Record keeping - five years under regulation 40 of the MLRs, running from the date an occasional transaction completes or from the end of a business relationship

Note the mismatch with VAT. Your VAT records run six years; your AML records five. Keep everything six and you are covered both ways.

The occasional transaction threshold also changed

The same 2026 amendment converted the occasional transaction threshold from €1,000 to £800. This is a different number doing a different job - it sits in regulation 27 and governs when customer due diligence obligations bite for certain occasional transactions - and it is easy to conflate with the £10,000 registration threshold. They are not the same test. If you are near either, get advice.

Do you register even if you rarely take big cash?

The trigger is accepting or making the payment, not doing it often. One £11,000 cash sale in a year puts you in scope for that sale.

You have two honest options:

  1. Register, and carry the fees, the risk assessment, the training and the annual declaration.
  2. Have a policy of not accepting cash at or near £10,000, apply it consistently, and take the balance by transfer.

Plenty of jewellers choose option two and set an internal ceiling well below the statutory one - £5,000 is a common line - precisely so that a linked-payment miscount can never push them over. That is a commercial decision, not a legal one, but it is a defensible way to run a shop.

What you cannot do is take the money and sort the registration out afterwards.

If you are already registered but no longer take cash

Being registered brings obligations regardless of what you actually bank. HMRC's handbook is clear that accepting only sub-threshold cash does not exempt a registered business from maintaining a current risk assessment and staff training. If you have stopped taking large cash entirely, deregistration is a conversation to have with HMRC rather than something to let drift.

Penalties

HMRC can impose civil penalties and, in serious cases, pursue prosecution for trading while unregistered or for failures in due diligence and record keeping. HMRC also publishes details of businesses penalised for non-compliance, which for a shop trading on its name is frequently the more expensive part.

We have deliberately not quoted a penalty figure here. The amounts are set case by case against turnover, culpability and duration, and any single number we gave you would be misleading.

Sources

This is general information, not legal advice. AML obligations are enforced against the individual business and the facts of its own trading. Take advice from a compliance professional or solicitor before deciding you are outside the regime, and check GOV.UK directly - some HMRC pages were still showing the old euro figure months after the sterling change took effect.

WatchCRM keeps a running total of linked cash payments per customer and warns at £9,000 rather than at the threshold, because a warning at £10,000 arrives after the money is on the counter. The AML record it builds is the same record HMRC asks to see.