Money laundering regulations have historically focused on cash transactions because cash is often the preferred method for criminals looking to disguise illegally obtained money. However, as financial crimes evolve, criminals increasingly exploit sectors dealing in high-value goods paid for digitally, making luxury interiors and furnishings attractive targets. High-end interior design projects often involve significant transactions, sophisticated clients, and valuable assets—exactly the type of scenario where money laundering risks can arise unnoticed.
This shift has prompted regulators to scrutinise high-value transactions more closely, irrespective of how the payment is made. Interior designers, whose business may involve substantial sums for bespoke furniture, artworks, custom fittings, and high-value decorative items, now find themselves at the forefront of regulatory attention. Understanding these developments is crucial not only for legal compliance but also for protecting the reputation and integrity of your business.
The term "High-Value Dealer" traditionally refers to any business trading in goods and accepting or making large cash payments—typically €10,000 (approximately £8,500) or more. Under UK regulations, HVDs have always been subject to stringent anti-money laundering obligations, including registering with HM Revenue & Customs (HMRC), verifying client identities, and maintaining detailed records of transactions.
However, regulators have begun to broaden their interpretation. While previously only cash payments triggered HVD obligations, there is a growing recognition that the risk of money laundering extends beyond physical cash. High-value transactions involving bank transfers, digital payments, or other financial methods can equally facilitate money laundering, prompting regulatory bodies to consider expanding the scope to include non-cash transactions.
The key regulatory shift is moving towards a value-based rather than cash-based approach. Businesses involved in transactions over €10,000—even those conducted entirely through bank transfers—are increasingly likely to fall under AML obligations. For luxury interior designers, this could mean needing to perform Customer Due Diligence (CDD) checks, maintain compliance records, and possibly register formally with HMRC.
Since January 2020, businesses dealing in high-value art (over €10,000), even if the payment is electronic, have become classified as Art Market Participants under UK law. This directly affects interior designers who regularly source or facilitate the purchase of valuable art and antiques for their clients. As an Art Market Participant, you must already be registered and compliant with AML rules, which include verifying identities and conducting enhanced due diligence for high-risk clients.
From May 2025, a significant new regulatory obligation comes into force regarding financial sanctions. Businesses making or receiving payments above €10,000 will be required to actively check their clients against UK and international sanctions lists. If a client is flagged as potentially sanctioned, you will have a legal obligation to report this immediately to the Office of Financial Sanctions Implementation (OFSI).
The reason behind these regulatory changes is multifaceted. Firstly, high-profile financial crime scandals involving sanctioned individuals—particularly linked to geopolitical crises such as Russian sanctions—have exposed vulnerabilities in luxury sectors. Authorities are responding to growing concerns that luxury markets are increasingly exploited to bypass traditional financial checks.
Secondly, the international community, including the Financial Action Task Force (FATF) and the UK government, is committed to tightening regulations to combat money laundering and terrorist financing effectively. Luxury goods, including high-end interior furnishings, are identified as potential targets for illicit wealth, driving a broader push towards enhanced transparency and compliance.
Finally, technological advancements and globalisation mean criminals can quickly and discreetly move illicit funds internationally. Regulators are therefore determined to adapt rules proactively, ensuring businesses involved in large-value transactions remain vigilant and accountable.
Luxury interior designers, due to the high-value nature of their work and the affluent clientele they typically serve, are particularly exposed to these regulatory changes. Many designers operate without realising the extent of their exposure under AML regulations, especially if they never handle cash. The new regulatory environment significantly expands the compliance responsibilities for these businesses, making awareness and preparation critical.
Compliance with AML regulations is no longer just about handling cash—it now encompasses all high-value transactions, irrespective of payment method. Designers must adapt by embedding rigorous client checks and sanctions screening into their client onboarding and transaction management processes. These requirements, although demanding, also offer an opportunity to demonstrate professionalism and reassure legitimate clients that you operate to the highest standards of integrity and compliance.
Interior designers should begin reviewing their business operations now. Assess whether your projects regularly involve high-value transactions, consider registering with HMRC if necessary, and understand your responsibilities under the new rules. Compliance is not optional; failure to adhere can result in substantial fines, reputational damage, and even criminal charges.
The next article in this series (Part 2: Practical Steps for Compliance) provides detailed guidance on the practical steps interior designers need to take, including how to perform customer due diligence, sanctions checking procedures, and essential record-keeping practices to ensure compliance and protect your business.
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.
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