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)?

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United Kingdom
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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 the UK is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the “Regulations”). The Regulations implement the Fifth European Anti-money Laundering Directive (Directive (EU) 2018/843).  

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

N/A

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?

There is no maximum amount of cash which a customer may use to purchase items in a store.

However, a business must not accept or make a high value payment unless they have registered with HM Revenue & Customs (HMRC) as a high value dealer.  A high value payment is:

  • a single cash payment of EUR 10,000 or more for goods;
  • several cash payments for a single transaction totalling EUR 10,000 or more, including a series of payments and payments on account; and/or
  • cash payments totalling EUR 10,000 or more which appear to have been broken down into smaller amounts so that they fall below the high value payment limit.

A business does not need to register if it:

  • only receives payments for services or for a mix of goods and services where the value of the goods is less than €10,000.
  • is only ever paid large amounts by credit card, debit card or cheque.

More information on registering with HMRC as a high value dealer can be found at Money laundering supervision for high value dealers - GOV.UK (www.gov.uk) 

Guidance for high value dealers on complying with their obligations under the money laundering regulations and related requirements can be found at: High value dealer guidance for money laundering supervision - GOV.UK (www.gov.uk)

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

There are no limitations with regard to the acceptance of denominations of banknotes in pound sterling (GBP), however it is worth noting that shops are entitled to refuse coins and banknotes at their sole discretion.

As above, transactions which fall under points 2 and 3 (i.e. individual smaller payments that amount to EUR 10,000 or more in total) in section 3 above, and are therefore high value payments, will mean that a business dealing in the goods and services and accepting (or making) the high value payment will need to register as a high value dealer with HMRC for money laundering supervision.

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?

A business cannot accept or make a high value payment unless they have registered with HM Revenue & Customs (HMRC) as a high value dealer.  See section 3.

Once a business has registered for money laundering supervision as a high value dealer, there is no duty to report individual instances of cash payments in excess of EUR 10,000 simply because they exceed this amount.

However, this does not exempt such a business from obligations (or mean they cannot be liable for offences) found under UK money laundering legislation. For example, the Proceeds of Crime Act 2002, which sets out the primary offences related to money laundering, makes it an offence to fail to report suspicious activity, as further detailed in the legislation. This applies to a high value dealer irrespective of whether the suspicion relates to a high value payment. Further, under the Terrorism Act 2000, regulated businesses such as high value dealers must report belief or suspicion of terrorist financing.  Further information can be found at Anti-money laundering supervision: guidance for high value dealers (publishing.service.gov.uk)

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

HMRC supervises high value dealers under the Regulations.

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?

See section 3.

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

For information about the penalties that HMRC can impose, please see Money laundering supervision appeals and penalties - GOV.UK (www.gov.uk).

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

N/A