Are you a business who deals with large sums of cash?

If you sell goods and accept €15,000 (around £12,500) or more in cash or virtual assets for a transaction, in one payment or several linked payments, you may be classed as a high value dealer under Jersey law and may need to register with us. 

Businesses commonly in scope include: 

  • jewellers  
  • car or yacht dealers  
  • art and antique dealers  
  • agricultural auctioneers  

If you think this might apply to your business, our team can guide you through the next steps. 

Contact us for more information and support

How to register with us 

You can register with us through myJFSC. 

Schedule 2 Forms 

How does registering with you protect my business? 

Businesses that accept large cash payments can be targeted by criminals seeking to hide the origin of illicit funds.  

When you register with us, we can help you protect your business and our island by helping you put simple safeguards in place, such as a business risk assessment, to prevent and detect financial crime. 

We supervise high-value dealers to prevent financial crime and keep individuals, businesses, and our island safe from money laundering.  

What is required of me if I register with you? 

To help protect people and businesses from financial crime, High Value Dealers must meet the requirements set out in the AML/CFT/CPF Handbook and the Money Laundering (Jersey) Order 2008. This includes having the right controls in place to help you identify, prevent and detect money laundering and related risks. 

Your supervisor will work with you to help you understand what this means for your business and to make sure you have suitable measures in place. These measures should be proportionate to the risks you face and help reduce the chance of your business being used for financial crime. 

If you would like more detail about the requirements that apply to you, please contact your supervisor at DNFBP/NPO/VASP@jerseyfsc.org. 

Awareness resources 

What to look out for 

Large or unusual transactions aren’t always suspicious, but some patterns may indicate that payments are linked or out of the ordinary. 

Linked transactions could include situations where: 

  • the same person or group makes several payments 
  • payments relate to the same item or purchase 
  • instalments over time total €15,000 (around £12,500) or more 
  • payments appear deliberately structured to avoid the threshold 

Examples of unusual activity 

  • unusually large or frequent cash payments 
  • delivery or payment methods that aren’t typical for your business 
  • customers with little trading history or no references 
  • customers travelling long distances to buy goods available near home 
  • multiple small cash deposits into your business’s bank account 
  • unusual questions about refund policies, for example, asking for refunds via cheque or bank transfer

Business risk assessments

What is a business risk assessment?

A business risk assessment (BRA) is an assessment of how exposed your business may be to certain financial crime threats and sets out how these threats and the associated risks are mitigated and reduced. 

Effectively, it establishes your formal approach to the day-to-day management of financial crime risks.

How do I create one?

A BRA is often set out as a table in Microsoft Excel (or similar spreadsheet software). This is one of the clearest ways to:

  • document and rate multiple risks
  • show that risks are not applicable to your business
  • show how risks are mitigated by the controls in place 

If you have a variety of customer types or activities, spreadsheets can help you apply calculations and, when necessary, develop other approaches using your spreadsheet as a first step. 

Note: a BRA is different to a customer risk assessment.

Specific risks to be aware of

Recognising stolen cash 

Stolen cash is frequently laundered through retail outlets. Sterling and many euro banknotes become stained with dye when cash boxes are stolen and opened during bank or cash-in-transit robberies. Criminals frequently attempt to clean the notes, but this damages the foil and other security features. 

High value cash transaction 

Money launderers want to move funds quickly to avoid detection. This is easily done in large one-off transactions. The purchase of high value goods, with good portability, paid for in cash, represents an attractive target for money launderers. 

Equally, an asset may be purchased to support a certain lifestyle, like a high-performance car or a yacht. Alternatively, an asset may be purchased as a form of long-term investment (for example, jewellery, an antique, a work of art etc.). 

Refunds 

Asking for a cash-purchased item to be refunded via cheque or electronic payment can be a way to turn criminal cash into legitimate funds. 

Suspicions may be raised if the customer:

  • enquires about the supervised person’s refund policy before purchasing
  • seeks a refund for spurious reasons
  • seeks the repayment in the form of a cheque or electronic payment when the purchase or a deposit was made in cash

Second-hand goods 

Businesses buying high value items (for example, jewellery, art, antiques) should be alert to the risk of stolen property entering the supply chain. 

Jewellers, art and antique dealers should inform their network and the police if they think stolen goods are being offered for sale locally. 

Behaviours to look out for

  • reluctance to make personal contact
  • reluctance to provide the required identification information or evidence of identity
  • customers who initially indicate that they will be paying for goods over €15,000 (around £12,500) by
  • credit card or cheque, and then at the last-minute present cash as the means of payment
    there appears to be no genuine reasons for paying large sums of money in cash
  • cash is unusual for that type of customer
  • customers purchasing goods which are available nearer home at a similar price
  • purchases by businesses where the level of cash activity is higher than the underlying business would justify
  • the customer is paying in small denomination used notes 

How to report your concerns 

If you are a registered High Value Dealer, you must submit a Suspicious Activity Report (SAR) to the Jersey Financial Intelligence Unit (JFIU) if you know or suspect that money is linked to criminal activity. 

Guidance on when and how to submit a SAR is set out in Section 8 of the AML/CFT/CPF Handbook.

Guidance documents

Case studies

Local Jersey operation

Mr A owned and ran a jewellery business which allowed him to facilitate the movement of criminal property from Jersey to the UK through the purchase and sale of bullion. This enabled cash to be removed from the Island under the cover of legitimate transactions, and without the cash being physically carried out of the jurisdiction.

The process was carried out in five steps:

  • a sum of cash, from the sale of drugs, would be handed to Mr A at his jewellery shop
  • Mr A would deposit that cash into his personal and business bank accounts
  • Mr A would use the cash to purchase gold bullion from a dealer based in Hatton Garden in London
  • the gold would be collected from the London dealer and sold for cash
  • the cash would then be available to UK-based members of the criminal enterprise to be used to buy drugs or to cover the operating costs of the enterprise

Mr A was convicted in late 2020 of money laundering in connection with the importation and supply of drugs in Jersey. The wider investigation resulted in the capture of drugs with a street value of £900,000.

Less common goods sold by high value dealers

A couple involved in the distribution and sale of drugs attempted to launder £20,000. They tried to exchange Jersey £20 notes into English notes, deposit the cash into UK bank accounts and buy goods to be re-sold later.

The couple initially approached local banks. The banks followed their internal policies on handling cash and refused to accept a cash deposit due to the amount and unexplained/undocumented source. The couple also approached a local car dealership. The dealership was not registered as a high value dealer as its policy did not take significant cash payments. They refused to sell vehicles for cash. The couple then decided to approach a smaller retailer stocking a wide range of electronics and they bought some expensive laptops, computers and smartphones.

The retailer was not registered as a high value dealer and did not have policies on accepting significant cash payments. So, despite the bill totalling over £20,000, the staff processing the transaction did not become suspicious and did not query the origin of the cash.

They accepted transactions that fall within the high value dealer definition in the Proceeds of Crime Law. If they were registered as a high value dealer, they would have appropriate systems and controls in place, apply customer due diligence (CDD) and BRA measures to the couple and may have been suspicious of the nature of the transaction.

The business in this example appears to be involved in money laundering and may be found guilty of the offence of dealing with criminals. As an unregistered high value dealer may be also found guilty of the offence of carrying on unauthorised specified Schedule 2 business. In addition, it appears that the business should have been registered with the JFSC so may be found to have broken Anti Money Laundering (AML) / Countering the Financing of Terrorism (CFT) Codes of Practice within the Handbook and may be subject to proceedings by the JFSC.

Group money laundering

A group of criminals held £50,000 in cash gained from drug trafficking. They targeted a high street jewellery business which held a high value dealer licence. Within a few days, each person in the group repeatedly visited the jewellery shop to purchase items. Whilst none of them spent more than £12,500 in a single transaction, together they laundered £50,000 into jewellery, which could then be enjoyed or re-sold for a profit.

The staff who took payments did not identify that the persons were operating together, and they did not consider the total amount spent by the group over multiple days.

If the business had more effective controls in place in line with the Handbook, they would have applied CDD measures and may have formed a suspicion that money laundering was taking place.

The business in this example appears to be involved in money laundering and may be found guilty of the offence of dealing with criminals.

The business failed to have relevant procedures to prevent and detect money laundering in line with the Money Laundering Order (MLO). They may be found guilty of an offence of contravening or failing to comply with a requirement contained in any Order made under Article 37 of the Proceeds of Crime Law.

In addition, the business may be found to have broken AML/CFT Codes of Practice within the Handbook and may be subject to proceedings by the JFSC.

Contact us 

Our team are here to support you if you’re unsure whether your business is classed as a high value dealer, or if you’d like help with registration or compliance. 

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Latest news 

See our latest news for high-value dealers. 

Glossary 

The terms in this glossary are simplified explanations for general understanding and should not be relied on as legal definitions. 

Business risk assessment (BRA): a Business Risk Assessment (BRA) is the process by which a High Value Dealer identifies and documents the money laundering, terrorist financing and proliferation financing risks to which its business is exposed. This assessment should take account of factors such as the nature of the goods sold, customer types, transaction patterns, geographic exposure and delivery channels. The risks identified in the BRA must be reflected in the business’s policies, procedures and controls, including Customer Risk Assessments. For further guidance, see Section 14 of the AML/CFT/CPF Handbook. 

Customer risk assessment (CRA): a Customer Risk Assessment (CRA) is an assessment carried out for each business relationship and, where required, for one‑off transactions. It enables a business to assess and document the level of financial crime risk associated with a particular customer, taking into account factors such as the customer’s background, the nature of the transaction and the source of funds. For further guidance, see Section 3 of the AML/CFT/CPF Handbook. 

Jersey law: under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 and the associated Money Laundering (Jersey) Order 2008, high-value dealers are required to register with us. 

Money laundering: the process of taking money gained illegally and making it appear as though it came from a legitimate source. 

Virtual assets: defined as a digital representation of value that can be digitally traded or transferred and can be used for payment or investment purposes. This includes digital currencies and other forms of digital assets that are used in transactions and investments.