1.  Please give details of any existing national legislation in your country that is specifically relevant regarding the obligations and limitations for LVMH shop assistants dealing with cash payments?
  2. Are there any changes or developments expected in the near future?
  3. Is there a maximum amount of cash a customer may use to purchase items in a store in your country? If yes, what is the amount?
  4.  Are there any limitations in your country with regard to the acceptance of denominations of [euro] banknotes?
  5.  Are there any rules in your country on partial and/or related cash payments and is it clear what can or will be seen as a partial and/or related payment?
  6.  Is there a duty to report to an authority if a customer would like to pay in cash above the maximum amount and/or with a denomination of a banknote which is forbidden?
  7.  What are the competent authorities which oversee the enforcement of the relevant legislation?
  8.  If there is a duty to report, what is the competent authority to report to and what are the relevant responsibilities of LVMH in that respect?
  9.  What sanctions do the authorities have at their disposal to make sure that companies comply with the rules?
  10.  Are there any other relevant developments or issues regarding this matter, of which LVMH should be aware (e.g. privacy issues)?

jurisdiction

Belgium
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1. Please give details of any existing national legislation in your country that is specifically relevant regarding the obligations and limitations for LVMH shop assistants dealing with cash payments?

The relevant legislation in Belgium is the Anti-Money Laundering Law of 18 September 2017, which is based upon the European Anti-money Laundering Directive (Directive UE 2018/843).

2. Are there any changes or developments expected in the near future?

No.

3. Is there a maximum amount of cash a customer may use to purchase items in a store in your country? If yes, what is the amount?

Yes, the maximum amount of cash a customer may use in Belgium is EUR 3,000.  If the price does not reach EUR 3,000, the customer can pay the full amount in cash. If the price reaches or goes above EUR 3,000, a payment in cash is allowed for up to 10% of the price to a maximum of EUR 3,000.

4. Are there any limitations in your country with regard to the acceptance of denominations of [euro] banknotes?

No. 

As mentioned above, if the price reaches or goes above EUR 3,000, a payment in cash is allowed for up to 10% of the price to a maximum of EUR 3,000. The limit of EUR 3,000 remains applicable for “several transactions that seem to be related”. The seller may not artificially divide a sale in several transactions under EUR 3,000 to avoid the prohibition.

6. Is there a duty to report to an authority if a customer would like to pay in cash above the maximum amount and/or with a denomination of a banknote which is forbidden?

Article 5 of the Anti-Money Laundering Law of 18 September 2017 defines the persons who are subject to the duty of customer and operation due diligence (with obligations under certain circumstances to report to the competent authority). LVMH does not belong to these categories.

7. What are the competent authorities which oversee the enforcement of the relevant legislation?

The Federal Public Service Economy, SMEs, Self-employed and EnergyCity, which is the Belgian authority responsible for monitoring compliance with the prohibitions of cash transactions above EUR 3,000.

8. If there is a duty to report, what is the competent authority to report to and what are the relevant responsibilities of LVMH in that respect?

As mentioned above, LVMH has no duty to report.

9. What sanctions do the authorities have at their disposal to make sure that companies comply with the rules?

A criminal fine of a maximum of 10% of the sum illegally paid in cash can be imposed on the parties. This fine cannot go above EUR 1.8 million. Both the seller and the buyer are liable for payment of the fine.

10. Are there any other relevant developments or issues regarding this matter, of which LVMH should be aware (e.g. privacy issues)?

No.