Cash Thresholds and AML Compliance Obligations for High-Value Dealers and Art Market Participants
When we published our previous guide on the Money Laundering Regulations 2026 changes now in place, one of the amendments we flagged was the switch from euro-denominated thresholds to sterling. For high-value dealers and art market participants, that is not just a footnote change; it sits at the very centre of how a regulated business of this nature decides whether the Regulations apply to a sale at all.
From 30 June 2026, the figure that defines a high value dealer is £10,000. The amending regulations substitute “£10,000” for “10,000 euros” wherever the old threshold appeared, converting on a one-to-one basis. No exchange rate, no rounding, no quarterly recalculation. On the face of it, this is the most welcome kind of regulatory change, as seemingly it makes the process simpler. However, regulated businesses are urged to pay attention to the detail. In this blog, our AML compliance team covers what changed and the points to be aware of.
What Actually Changed on 30 June
A high-value dealer is defined under regulation 14 of the MLR 2017 as a business that trades in goods and, in respect of any transaction, makes or receives a cash payment of at least the threshold amount, whether in a single operation or in several linked operations.
Until 30 June, that threshold was 10,000 euros. Therefore, if your clients paid your invoices in pounds, you were expected to work out whether a given sterling sum crossed a euro line that moved with the exchange rate. A £8,700 cash payment might be inside the net one week and outside it the next, depending on what the euro was doing. It was an awkward, error-prone way to run a compliance trigger, and it is now gone.
The threshold is now a flat £10,000 in cash. That is the number your staff need to know, and it is the number HMRC will apply.
Two points are worth being clear about, because they are where businesses tend to trip up.
First, the £10,000 figure is slightly higher in sterling terms than the euro threshold it replaces. For most of the past two years, 10,000 euros converted to somewhere in the region of £8,400 to £8,700. So, a handful of transactions that would have been caught under the old rule now sit just below the line.
Second, the trigger has always been about cash. Card payments, bank transfers and cheques do not count towards it, however large (though regular banking AML rules still apply to electronic movements of large sums). A £40,000 sale settled by bank transfer does not make you a high value dealer, whereas the same sale settled with £40,000 in notes will apply.
Linked Transactions: Where the Real Risk Lives
The single most misunderstood part of the high value dealer regime is the word “linked”. The threshold has never been about one payment. It is about a transaction, and a transaction can be made up of multiple smaller cash payments.
HMRC’s own guidance sets this out plainly. If a customer buys a car and pays it off in monthly cash instalments of £2,000 across a year, those payments are linked, and once they pass £10,000 in total the transaction is within scope. The instalments never individually approach the threshold, but that is irrelevant. They belong to one sale.
The second form of linking is the one HMRC watches most closely, because it shades into deliberate evasion. If a customer buys four separate pallets of the same goods priced at £5,000 each and asks for four separate £5,000 invoices rather than a single £20,000 one, the paperwork has been arranged to keep each item below the trigger.
The total cash is still £20,000; the goods would normally sit on one invoice, and HMRC treats the whole thing as a single linked transaction. Splitting the invoice does not split the obligation. What it does do, if a supervisor spots it, is turn an ordinary sale into evidence that the business understood the threshold and structured around it.
For galleries, auction houses, and other high-end dealers, this is a crucial aspect to be aware of. A client who wants to settle a £30,000 acquisition in three cash payments across three visits is not automatically doing anything wrong, but the transaction is linked; it is caught within the high-value dealer threshold, and the due diligence obligations attach to all of it. It is not about whether any single payment is £10,000; it is about whether the whole transaction involves £10,000 or more in case.
The Discretion Problem for Galleries and Auction Houses
The art market carries a particular tension that most other high-value dealer sectors do not, and the threshold change brings it into sharper focus.
Often high-net-worth clients and collectors value privacy; provenance conversations are handled delicately, and the relationship between a gallery and a serious buyer is built on not asking more than you need to. Anti-money laundering compliance is the complete opposite. The regulations require you to establish who your customer is, understand the source of their funds, and document all of it, precisely at the moment a client expects you to be least intrusive.
An expectation of confidentiality from a client is not an excuse, and the Regulations do not accept discretion as a defence. Where a cash transaction reaches the £10,000 trigger, customer due diligence is required regardless of how well you know the buyer or how sensitive the sale. Art market participants have been within the AML regime since January 2020, and HMRC has shown it is willing to act. In the enforcement round we covered in AML Failures Catching Regulated Businesses Out, the art dealer Unit London was fined £20,000, not for a laundering failure but for failing to keep its nominated officer details up to date. The lesson from the HMRC here is clear, the regulator does not need to find a deliberate case of money laundering to impose a penalty. It only needs to find that the risk management controls were not in place or were not recorded.
There is also a source-of-funds dimension that art businesses share with the property sector. Establishing that a buyer can afford a piece is not the same as establishing where the specific money came from, and the two are routinely conflated. We unpicked that distinction for estate and letting agents in Source of Funds vs Source of Wealth, and the same logic applies squarely to a six-figure cash-assisted art sale.
What HVDs and Art Market Participants Should Do Now
The amendments are intended to make the AML regime more proportionate, but that does not reduce a firm’s compliance responsibilities. Steps businesses should be taking include:
- Update the number everywhere it appears. Point-of-sale guidance, staff training notes, till prompts, and your policies, controls and procedures should now say £10,000, not 10,000 euros or any sterling estimate of it. Anyone on the floor who takes cash needs to recognise the trigger without doing mental arithmetic.
- Train staff to spot linking, not just large payments. The person most likely to miss a linked transaction is the one who only watches for a single payment above the threshold. Instalments and split invoices are where the risk sits, and frontline staff are the ones who see them first.
- Have a documented position on cash. Many high-value dealers are choosing to cap or decline cash above a set level altogether. Whether or not you go that far, your approach to cash should be a deliberate, recorded decision rather than something that varies by whoever is serving.
- Revisit your risk assessment. A change in the trigger is a change in your risk profile, and a risk assessment that still references the euro threshold is out of date. HMRC treats an outdated risk assessment as a failure in its own right.
- Check your registration and officer details. As the Unit London penalty shows, administrative gaps around registration and nominated officers attract fines regardless of whether any suspicious activity ever occurred.
Confirm You Are Compliant with a Regulation 21 Audit
For most high-value dealers and art market participants, the practical question is not whether the threshold moved but whether the whole AML framework behind it still holds together. A policy document that references the wrong figure, staff who watch for the wrong trigger, and a risk assessment written for the old regime are exactly the kind of gaps an independent audit is designed to surface before a supervisor does.
An independent audit under Regulation 21 of the MLR 2017 gives a business confidence that its policies, controls and procedures are compliant and working in practice. For any business above the micro business level, it is a core part of compliance management and a document that protects you in the event of an HMRC enquiry. We explain who needs one, and where the line sits, in Do You Need a Regulation 21 AML Audit? Most Regulated Businesses Do.
RACO carries out Regulation 21 audits for businesses of every size and across every regulated sector, including high-value dealers and art market participants. You can download the service brochure here: RACO Regulation 21 Independent Audit for Regulated Businesses.
Speak to Our Compliance Team
To discuss how the 2026 threshold change affects your business, or to book a Regulation 21 Independent Audit, call us on 0203 985 8550 or email us at
info@regulationandcomplianceoffice.co.uk
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