A death-knell for HVDs

Last week I went to a funeral, and as I sat outside the crematorium waiting for it to begin, I observed the rather large number of undertakers in attendance.  The funeral business is manpower heavy, what with the preparation of the body and the paperwork and the actual physical work of carrying the coffin, driving the hearse and mourners’ cars and walking in front of the cortège.  Add to this the cost of chapel rental and flowers, and the price of a funeral soon mounts up.  In fact, research earlier this year suggested that the average cost of funeral in the UK is now nearly £3,500.  So for those who go the whole hog it can be a significant expense – we’ve all seen the photos of the old East End funerals, such as Charlie Richardson’s in October 2012.

So why my morbid turn on mind?  Well, in the draft Fourth Money Laundering Directive, one of the changes that seems to have escaped general notice and concern comes in the latest amendment to draft revised Article 2 (do keep up – it’s a long process, and there’s more to come).  Article 2 deals with the “obliged entities” (i.e. those who will be required to abide by AML legislation) and the latest version of it says this: “Other natural or legal persons trading in goods or services, only to the extent that payments are made or received in cash in an amount of €7,500 or more, whether the transaction is executed in a single operation or in several operations which appear to be linked”.  Now, I’ve mentioned this before, but I think it’s quite significant – because it lowers the threshold for all high value dealers (it used to be €15,000), and because it brings in those dealers in services.  And last week, for the first time, I realised that this might include undertakers as well.  You see: I got there in the end.

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4 Responses to A death-knell for HVDs

  1. Nick Smith says:

    Hi Susan, I hope you’re well, what are your thoughts on people who supply goods and services e.g. Kitchen fitter who also sells the units or Firework Display people who also supply the fireworks?


    • Welcome to the blog, Nick, and thank you for your comment. As I understand it, it’s all about supplying goods for cash. So if a kitchen fitter (actually quite a common scenario, this one – less so the fireworks!) supplies units and then fits them, the element that might HVD-ify him is the sale of the units (as the fitting is the supply of a service, which is not HVD-able). If the goods part of the deal totals £10,000 or more and the customer pays in cash, then it’s caught. There have been instances where tradespeople have “adjusted” their invoices so that the goods part is small and the majority of the charge is made for the service element… Best wishes from Susan

      • Nick Smith says:

        That’s great Susan, thanks, what the fireworks, because they’ll be used as part of the service, still goods, even though no lasting value?

  2. You may want to take legal advice on this, Nick, if it’s crucial, but my view would be that the fireworks are still goods rather than a service: I assume that the invoice to the customer will show how much they are paying for the fireworks and how much for the service of creating the display…?

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