Anti-Money-Laundering Rules for Jewellers: The High Value Dealer Regime

Most jewellers assume anti-money-laundering law is a big-bank problem, or something that only bites the Bond Street end of the trade. It isn't. The High Value Dealer regime doesn't care how expensive your stock is or how well-heeled your customers are. It cares about one thing: cash. The moment you accept — or pay out — £10,000 or more in notes and coins for goods, you are supposed to already be registered with HMRC. Not soon. Already, before the money changes hands.

That single fact reframes the subject. This is not a regime about being a high-end dealer; it is a regime about handling large amounts of cash. The practical question for most independents is not "how do I comply?" but "do I want to accept that kind of cash at all?"

The trigger is cash, not price

A High Value Dealer, defined in Regulation 14 of the Money Laundering Regulations 2017, is any firm or sole trader who, in the course of business trading in goods, makes or receives a payment in cash of at least £10,000 in respect of a transaction.

Read that carefully, because the word doing the work is cash. Cash means notes, coins and travellers' cheques, in any currency. A £14,000 engagement ring paid for by card or bank transfer does not touch the regime at all. The same ring paid for with a bag of twenties does. You can sell a Patek Philippe every week of the year and never become a High Value Dealer, provided the money arrives electronically.

So the regime is not a tax on selling luxury. It is a control on physical cash — what launderers need to convert into something clean, portable and resaleable. A watch or a diamond is close to ideal for that.

£10,000 — and, as of this summer, literally £10,000

Here is where a lot of published advice is now out of date, and worth flagging because it changed only weeks ago. For years the threshold was defined as €10,000 or more, or the equivalent in any currency — a euro figure that floated with the exchange rate, and plenty of accountants' guides still quote it.

As of 30 June 2026, an amendment (SI 2026/621) converted the thresholds from euros to sterling. The in-force wording of Regulation 14 now reads a plain £10,000. If a source still says "€10,000 or equivalent," treat it as pre-July 2026 and check the current regulation on legislation.gov.uk before relying on it.

The threshold applies whether the £10,000 is paid in a single operation or in several operations which appear to be linked. That linked-transactions rule catches people out. Taking £6,000 today and £5,000 next month against the same ring is one transaction of £11,000, not two payments under the limit. And deliberately splitting a payment to stay under £10,000 does not put you outside the regime — it puts you inside it, and marks the transaction as suspicious.

"Makes or receives" — the scrap-gold trap

Re-read the definition: the trader who makes or receives a payment in cash. Most jewellers read only the "receives" half and picture a customer paying them. The "makes" half quietly catches the second-hand and scrap side of the business.

If you buy in old gold, estate pieces or scrap and pay the seller £10,000 or more in cash, you have made a high-value cash payment — and triggered the regime just as surely as a customer paying you. A shop that would never take a five-figure cash sale can still walk into the rules through the buying counter. If you run a "we buy gold" operation, this is the exposure to check first.

Register first, trade second

The sequencing is strict and counter-intuitive. You cannot accept or make a relevant cash payment and then register; you must be registered with HMRC before the payment happens. Trading as an unregistered High Value Dealer is itself the offence — separate from anything to do with the money actually being dirty.

Registration is done through HMRC's anti-money-laundering supervision service. HMRC is your supervisor here — not the FCA, which supervises a different population. You apply, name your premises, pass HMRC's approval checks on the relevant owners and managers, and pay the fees before you start.

What registration actually commits you to

Registration is the beginning, not the end. The regulations then expect a working compliance programme — proportionate to a small business, but real:

• A written risk assessment. Identify and assess, in writing, where your business is exposed to money-laundering risk, and keep it current.
• Policies, controls and procedures. Documented processes flowing from that risk assessment, plus staff training so people know what to watch for.
• Customer due diligence. For relevant transactions you must identify and verify the customer, identify any beneficial owner, and understand the purpose and nature of the dealing — with enhanced checks where the risk is higher. In plain terms: know who you are dealing with, and why they are paying in cash.
• A nominated officer. Someone appointed to receive internal reports and, where warranted, submit Suspicious Activity Reports to the National Crime Agency. In a small shop that person is usually the owner.
• Record-keeping for five years. You keep the due-diligence records and transaction documents for five years from the end of the relationship or the transaction — and the regulations expect you to delete them after that, so retention is a discipline in both directions.

None of this is exotic, but it is ongoing — a standing overhead on the business, not a one-off form.

What it costs

The headline fees are modest, revised on 1 December 2025. There is a one-off, non-refundable application fee of £300. On top of that you pay an annual premises fee — £400 for each premises on your registration — and around £40 per person for HMRC's approval check on relevant owners and managers.

There is a small-business reduction, but read the small print: it applies where turnover is under £5,000, which describes a dormant or hobby trader, not a working high-street shop. For any real jeweller, budget the full £300 plus £400 per premises every year, plus your own time on the paperwork and the annual declaration.

The penalties are mostly for not registering at all

The enforcement pattern is the tell. HMRC's own figures show more than nine in ten of its anti-money-laundering penalties relate to businesses trading without being registered, rather than to sophisticated laundering. In the six months to September 2025, HMRC issued 369 penalties totalling just over £1.88 million, most for that basic failure to register.

Contravening the regulations is not merely a civil matter. It can be prosecuted as a criminal offence carrying, on conviction, up to two years' imprisonment, a fine, or both — the penalty for breaching the money-laundering rules themselves, distinct from the far heavier sentences that attach to actually laundering criminal proceeds. The point for an ordinary jeweller is simpler: the person most likely to get caught by this regime is not a launderer. It is an honest dealer who took a big cash payment without registering first.

The sensible position for a small shop

Here is the contrarian conclusion the fee schedule and enforcement data both point to: for most independents, the right move is to stay out of the regime entirely, by choice.

You are only a High Value Dealer if you accept or make cash payments at or above the threshold. Set a firm policy that you do not take cash — or make scrap payouts — of £10,000 or more, steer those customers to card or bank transfer, and you are outside the rules altogether. No registration, no annual fee, no due-diligence file. For a shop with no particular need to handle five-figure cash, that is cleaner, cheaper and lower-risk than registering.

Registration makes sense only if accepting large cash is genuinely part of how you trade — a busy buying counter, a clientele that pays in notes — and you have decided that business is worth the standing overhead. That is a legitimate choice. It is just a choice, and it should be made deliberately rather than backed into by a single transaction on a busy Saturday.

The bottom line

The High Value Dealer regime is narrower than its reputation and stricter than its paperwork suggests. It is not about being posh; it is about £10,000 in cash, in or out, in one payment or several linked ones. If that is not a business you need, write a no-large-cash rule, apply it at both counters, and forget the regime exists. If it is a business you want, register with HMRC before the first qualifying payment — never after. Because the one position that reliably gets punished is the middle one: taking the cash, and sorting out registration later. When it comes to money you cannot verify, the safest answer is usually the card machine.