Most honest businesses rarely think about money laundering, but the law expects you to stay alert when money comes in. In England and Wales, some money laundering offences apply to everyone, and certain sectors have additional, active duties. Here is what receiving payment can mean for your legal obligations, in plain English.
The offences that apply to everyone
The Proceeds of Crime Act 2002 (POCA) creates money laundering offences that are not limited to banks or regulated firms, they can apply to any business or individual. In broad terms, it can be an offence to acquire, use, possess, or deal with property that you know or suspect represents the proceeds of crime. So if a payment makes you genuinely suspicious that the money is criminal, processing it anyway can expose you to liability.
Extra duties for "regulated" businesses
If your business is in a regulated sector under the Money Laundering Regulations 2017 (such as accountants, estate agents, certain financial, legal and trust/company service providers) you have additional duties, including:
- customer due diligence (verifying who your customer is, and understanding the source of funds);
- a risk-based approach, with enhanced checks for higher-risk situations;
- a nominated officer and written AML policies and training; and
- submitting a Suspicious Activity Report (SAR) to the National Crime Agency where you know or suspect money laundering, and not "tipping off" the customer.
High-value cash payments
If you trade in goods and accept large cash payments (the threshold is €10,000 / £10,000 or more in a single transaction or linked transactions), you may be a "high-value dealer" and need to register and apply AML controls, another reason to think before accepting big cash sums.
Red flags to watch for
- payments from an unconnected third party with no obvious reason;
- unusually large cash payments, or amounts that don't fit the customer;
- funds routed through multiple accounts or unexpected jurisdictions;
- a customer who is evasive about the source of funds or who is paying.
Practical steps
- Know whether your business is in a regulated sector; if so, follow your AML procedures.
- For everyone: ask questions about anything that looks odd, and keep records.
- If you suspect money laundering, don't just proceed, take advice, and (if regulated) report via a SAR.
- Have a clear policy on cash limits and third-party payments.
Key takeaways
- POCA 2002 money laundering offences apply to all businesses, not just regulated ones.
- Regulated firms must also meet the Money Laundering Regulations 2017 (due diligence, risk-based approach, SARs).
- Large cash payments (€10,000/£10,000+) can make you a high-value dealer with AML duties.
- Stay alert to red flags, ask questions, keep records, and report suspicions where required.
Sources
- Proceeds of Crime Act 2002 (money laundering offences)
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- National Crime Agency (Suspicious Activity Reports); high-value dealer registration
--- This article is general information about the law of England & Wales as at 2026, not legal advice. For advice on your circumstances, consult a qualified solicitor or your AML supervisor.