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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