SOAS Research Online

Abstract

The Money Laundering Regulations 2003 came into force in the early part of 2004 in order to implement the EU Second Money Laundering Directive. They are much wider-ranging than the 1993 Regulations, which had preceded them: in addition to banks and other financial institutions, which were already covered, and bureaux de change and money transmission offices, added in 2001, they also apply to, inter alia, lawyers, accountants, estate agents, casinos and dealers in high value goods, such as jewellers and art dealers. Dealers in high value goods, however, are only covered in respect of transactions which are of a value of at least €15,000 and, moreover, in cash. That customers will be dealt with differently, in respect of the same transaction, depending on how payment is made, is unfortunate. A threshold stated in sterling would also be preferable: jewellers are often less well used to dealing in other currencies than financial institutions. More generally, if particular care is seen as required in relation to cash transactions, the threshold should arguably be lower. The actual requirements imposed have, however, changed little: the only major change is that certain types of business now need to be registered with Customs & Excise.