What this guidebook covers
Cars are a known way to launder cash. Any business that accepts €10,000 or more in cash, in one payment or linked payments, is a high value dealer and must register with HMRC and follow the Money Laundering Regulations. One cash sale can change a dealer's status.
This guidebook covers 6 AML standards with 18 checkpoints: a cash policy or HVD registration, monitoring linked payments, the risk assessment and policies, customer due diligence, suspicious activity reports, and training and records.
The 6 anti-money laundering standards
| Code | Standard | Ideal fix time |
|---|---|---|
| AML-01 | Cash policy or HVD registration | Immediate |
| AML-02 | Linked payments monitored | 7 days |
| AML-03 | Risk assessment and policies | 30 days |
| AML-04 | Customer due diligence | Immediate |
| AML-05 | Suspicious activity reports | Immediate |
| AML-06 | Training and records | 30 days |
How to run a UK anti-money laundering audit, step by step
- Confirm what applies. Decide whether you cap cash below the threshold or register as a high value dealer; most dealers avoid HVD status with a firm cash cap.
- Walk the site, standard by standard. Score each of the 18 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Sample cash receipts and look for linked payments from the same customer that together pass the threshold.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: the cash policy, cash receipts, HVD registration if any, customer ID records and training logs.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Dealer principals
- Finance and sales managers
- Compliance officers
- Auditors
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
