Threshold transactions are transactions that, by reaching or exceeding a defined monetary value, trigger specific anti-money-laundering obligations. The key point for UK firms is that the UK regime works differently from regimes such as the United States. There is no general mandatory cash-transaction reporting threshold in the UK; instead, certain thresholds trigger customer due diligence, and large cash movements are treated as risk indicators within a risk-based system.
UK thresholds that trigger obligations
Under the Money Laundering Regulations 2017, customer due diligence must be carried out for occasional transactions of EUR 15,000 or more under Regulation 27(2). Businesses trading in goods become “high-value dealers”, and therefore regulated, when they make or receive cash payments of EUR 10,000 or more under Regulation 14. These thresholds trigger due diligence; they are not automatic reporting triggers.
Why the distinction matters
In the US, a cash transaction over USD 10,000 generates a mandatory Currency Transaction Report regardless of suspicion. The UK takes a suspicion-based approach: under the Proceeds of Crime Act 2002, a regulated firm must report where it knows or suspects, or has reasonable grounds to suspect, money laundering, whatever the amount. A large cash deposit is therefore a red flag that should prompt enhanced scrutiny and may lead to a Suspicious Activity Report, but the threshold itself does not compel a report. Staff trained on US rules can wrongly assume an automatic filing duty, so this is an important training point.
Who it applies to
All regulated-sector firms under the MLRs 2017, and particularly high-value dealers and cash-intensive businesses.