A High‑Value Dealer (HVD) is a business that trades in goods and accepts payments of €10,000 or more. Historically, this applied only to cash payments. Regulators now recognise that high-value transactions via bank transfers or digital payments also pose illicit finance risks and may require AML compliance actions similar to HVDs.
Criminals increasingly use non-cash methods to launder large amounts - making sectors like interior design, art, and luxury goods prime targets. Therefore, AML scrutiny is shifting to a value-based approach, encompassing all high-value payments regardless of how they are made.
Since January 2020, businesses dealing in high-value art (over €10,000) are classed as Art Market Participants and already subject to AML rules. From May 2025, all high-value transactions (not just cash) will require client sanctions screening - meaning businesses must check against UK and international sanctions lists and report matches to the Office of Financial Sanctions Implementation (OFSI).
Q: Does this only apply to cash now?
A: No - regulators now class large non-cash payments as high-risk too, meaning AML obligations can be triggered by high-value transfers, not just cash.
Q: What new compliance came into force for May 2025?
A: Sanctions screening. Any transaction over €10,000 requires client screening against sanctions lists, and reporting to OFSI if there are matches
dospay is a trading name of DOS & Co. Ltd, a company registered in England and Wales with company number 08294966.
DOS & Co. Ltd. is registered with the Financial Conduct Authority under the Payment Services Regulations 2017 (FRN: 833374) for the provision of payment services.
All of our GBP escrow and third-party managed accounts are segregated and safeguarded at the Bank of England.
